Declaration of Gerry Armstrong

RTC v. Ward, Henson & Erlich

Image of signature page



Religious Technology Center,



Grady Ward,


Religious Technology Center,



H. Keith Henson,


Religious Technology Center, et al.,



Dennis Erlich, et al.,



NO. C-96-20207 RMW






NO. C-96-20271 RMW





NO. C-95-20091 RMW


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 writer, artist and philosopher.Theologically speaking I am a prophet. Speaking religiously, I am a Christian.

3. I am an expert and have testified as an expert in the areas of the Scientology organization's structure, nature, philosophy, policies, practices, history, specifically regarding its notorious fair game doctrine, its fraudulent representations, its legal abuses and tactics, and its "theology." I have testified, either in deposition or trial, over 60 days in approximately 20 Scientology related cases. I have written and executed dozens of declarations, which I will supply the Court if requested, concerning my Scientology knowledge and experiences. I have stated most of the facts contained in this declaration in these earlier sworn statements.

4. I have been sued by the Scientology organization five times since 1982 in its continuing effort to prevent me from speaking the truth and to destroy me financially. I have been throughout this time a world-wide target of Scientology's character assassination campaign or "black propaganda," which it also calls "dead agenting." To "dead agent" someone, according to Scientology founder L. Ron Hubbard, is to destroy a target's credibility so that someone else "kills" him. I will list some of these acts below. Scientology is controlled and directed by David Miscavige.

5. Within the past three weeks I have obtained an internet account and have started reading the newsgroup alt.religion.scientology. Grady Ward, defendant herein, posted a request for declarations concerning knowledge of fair game operations, and


specifically ops involving organization private investigator Eugene M. Ingram. Mr. Ward stated that the declarations are needed fairly urgently. I have such knowledge, some of which I will provide below. I am aware of the related cases before this Court, RTC v. Erlich, and RTC v. Henson, and will also provide this declaration to those parties.

6. I am submitting this declaration directly to the Court because of an order filed October 17, 1995, a true and correct copy of which is attached herewith as Exhibit [A], in the case of Scientology v. Gerald Armstrong, Marin Superior Court Case No. 157680 ("Armstrong IV"). By that order, which became part of a " judgment" filed May 2, 1996, a true and correct copy of which is attached herewith as Exhibit [B], I am prohibited from:

" 2. Voluntarily assisting any person (not a government organ or entity) defending a claim, intending to defend a claim, intending to defend an arbitration, or intending to defend any claim being pressed, made, arbitrated or litigated by any of the Beneficiaries, regarding such claim or regarding defending, arbitrating, or litigating against it;
3. Voluntarily assisting any person (not a government organ or entity) arbitrating, or litigating adversely to any of the Beneficiaries;" (Ex. A, 8:1-7)

7. The " Beneficiaries" are:

-The Church of Scientology International, its officers, directors, agents, representatives, employees, volunteers, successors, assigns and legal counsel;

-The Church of Scientology of California, its officers, directors, agents, representatives, employees, volunteers,


successors, assigns and legal counsel;

-Religious Technology Center, its officers, directors, agents, representatives, employees, volunteers, successors, assigns and legal counsel;

-The Church of Spiritual Technology, its officers, directors, agents, representatives, employees, volunteers, successors, assigns and legal counsel;

-All Scientology and Scientology affiliated Churches, organizations and entities, and their officers, directors, agents, representatives, employees, volunteers, successors, assigns and legal counsel;

-Author Services, Inc., its officers, directors, agents, representatives, employees, volunteers, successors, assigns and legal counsel;

-The Estate of L. Ron Hubbard, its executor, beneficiaries, heirs, representatives, and legal counsel;


-Mary Sue Hubbard;" (Ex. A, 7:8-28).

8. By this order I am prohibited from providing this declaration to Mr. Ward, Mr. Erlich or Mr. Henson for their defense, since the plaintiff RTC is one of the "beneficiaries." Eugene Ingram, being Scientology's agent, is a protected "beneficiary" as well, as are all of its corporations' attorneys, including its attorneys herein.

9. I am also prohibited by this order from "5.Discussing with anyone, not a member of [my] immediate family or [my] attorney, Scientology, the Church, and/or any of the Beneficiaries;" (Ex. A, 8:14-16) Thus, I may not even, and remain in compliance with this order,


tell Mr. Ward, Mr. Erlich, Mr. Henson, or anyone else being persecuted by the Scientology organization with its well known and well greased fair game machinery and operatives, one word of my knowledge concerning these persecutors, or that I am myself so persecuted.

10. This order does not, however, prohibit me from voluntarily assisting a person judging litigations involving the order's "beneficiaries." I believe that the United States District Court is a "governmental organ or entity" excluded from the prohibitions of the order. (See, Ex. A, 8:1,2; 6,7) I am therefor providing the original of this declaration to the Court. I also believe that it would be improper to send this declaration to the Court in secret, thus I am sending copies to the parties or their counsel.

11. I believe the order and judgment are illegal on their faces, and obtained by Scientology through illegal tactics. The "contract" which the "order" enforces was obtained by Scientology through threat, fraud, related criminal activities, and the vitiation of my lawyers. I have appealed the judgment, and believe that I will prevail and be free from Scientology's very damaging, illegal and evil efforts to keep me suppressed and defenseless. In the meantime, I am by this declaration making known some of Scientology's abuses, one of which is this order itself, and I am working for their cessation, for safety, peace and sanity on whatever channels remain to me. I know that certain of Scientology's leaders and agents are vindictive, desperate and dangerous, and have targeted me as a major"enemy." I believe I am in considerable physical danger at this time. What Scientology's leaders have done and ordered done to suppress


and destroy me in the past 15 years is unbelievable, and these people evidence a continuing determination to keep that history of suppression and destruction from ever being believed or even known.

12. Attached hereto as Exhibit [C] is a true and correct copy of a document entitled "Mutual Release of All Claims and Settlement Agreement," (hereinafter, quot;"settlement agreement"") which was part of the December, 1986 "settlement" of my cross-complaint in the first case in which Scientology sued me in 1982, Scientology v. Armstrong, Los Angeles Superior Court Case No. 420153 ("Armstrong I"). Scientology's judicial enforcement of the "settlement agreement" resulted in the order and judgment appended hereto as Exhibits A and B. I will describe in paras. 22 through 32 below how Scientology obtained my signature on this document.

13. I became involved with Scientology as a customer in 1969 in Vancouver, B.C. I worked on staff there in 1970, and in February 1971 joined the Sea Organization ("Sea Org" or " SO") in Los Angeles. I was flown to Spain and joined the Sea Org's flag ship, "Apollo," in Morocco. L. Ron Hubbard, the SO's "Commodore," and all of Scientology's supreme leader, was on board and operated Scientology internationally through the " crew" which numbered, during my stay on board of four and a half years, around four hundred. All my staff positions on board involved personal contact with L. Ron Hubbard, Mary Sue Hubbard, administrative organization staff, and people in the ports and countries the "Apollo" visited, and included "Ship's Representative" (legal officer), "Port Captain" (public relations officer), and "Intelligence Officer."


14. In the fall of 1975, after the ship operation moved ashore in Florida, I was posted in the Guardian's Office (GO) Intelligence Bureau connected to Hubbard's Personal Office. From December 1975 through June 1976 I held the post of Deputy LRH External Communications Aide, a relay terminal for Hubbard's written and telex traffic to and from Scientology organizations. From July 1976 to December 1977 I was assigned, on Hubbard's order, to the Rehabilitation Project Force ("RPF"), the SO prison system, in Clearwater, Florida. In 1978 I worked in Hubbard's cinematography crew in La Quinta, California making movies under his direction until the fall of that year when he again assigned me to the RPF, this time for eight months, initially in La Quinta, then at a newly purchased base at Gilman Hotsprings near Hemet, California. When I got out of the RPF in the spring of 1979, and until the beginning of 1980, I worked in Hubbard's "Household Unit" ("HU") at Gilman, the SO unit which took care of Hubbard's house, personal effects, transport, meals and so forth. My posts included "Purchaser," "LRH Renovations In- Charge" and "Deputy Commanding Officer HU."

15. Throughout 1980, and until I left the organization in December 1981, I held the organization posts in Hubbard's "Personal Public Relations Bureau" of "LRH Archivist" and "LRH Personal Researcher." I assembled in Los Angeles an archive of Hubbard's writings and other materials relating to his history to be used as the basis for a biography to be written about the man. I also worked in Los Angeles for the first few months of 1980 on Mission Corporate Category Sortout ("MCCS"), which had the purpose of restructuring the Scientology enterprise so that Hubbard could continue to control it without being liable for its


actions. Beginning in the fall of 1980 and continuing until my departure, I provided the biographical writings and other materials, as I collected and organized them, to a non-scientologist writer Omar Garrison, who had contracted with the organization to write the Hubbard biography. I interviewed many people who had known Mr. Hubbard at periods throughout his life, including almost all of his living relatives. I traveled several thousand miles collecting biographical information and conducting a genealogy search, and arranged the purchase of a number of collections of Hubbard-related documents and other materials from individual collectors.

16. Through my research and study of documentary evidence I learned that Mr. Hubbard had lied about his past, credentials, accomplishments, relationships and intentions. I disproved many of the claims made by Hubbard in his biographies printed in Scientology publications and used in promotion of the man and his philosophy and psychotherapy, and attempted to get the organization executives responsible for these publications to correct the false claims. As a result I was deemed a threat, and ordered to be "security checked," an interrogation employing an electronic meter as a lie detector, a procedure I had undergone many times in the Sea Org. I had by this time also debunked the significant representations Hubbard had made about himself or his "technology" which had drawn me into and kept me in the organization for over twelve years; e.g., that he was an engineer and an atomic physicist; that he had been crippled and blinded in combat in World War II and had cured himself with his mental science discoveries; that it was a matter of medical record that he had twice been pronounced dead; that his psychotherapy had


been subjected to rigorous scientific testing; that it cured all psychosomatic ills and raised IQs a point per hour of therapy (I had by this time had well over a thousand hours); that he had been remunerated for his labors less than staff members were paid (in my case between $4.30 and $17.20 per week throughout my SO years); and that he and his organization were ethical and well-intentioned. When it became clear to me that I was not going to be able to get the organization or Hubbard to admit to the lies and take a more honest path I left, along with my then wife Jocelyn.

17. Following my departure the organization published a "Declaration" dated February 18, 1982 labelling me a "Suppressive Person ("SP")." An SP is considered in Scientology completely psychotic and destructive, one of the two and a half percent truly evil people on the planet. SPs are viewed as enemies of Scientology and mankind and are targets for the organization's "Fair Game Policy," which states specifically that they may be lied to, cheated, sued and destroyed without discipline of the Scientologist committing such acts. The "SP Declare" on me also accused me of "spreading destructive rumors about senior Scientologists." I knew in early 1982 that I was the target of Guardian's Office intelligence operations because certain friends were contacted and interrogated about me by known GO intelligence personnel. In April, 1982 the organization also illegally appropriated a set of photographs I had entrusted with an associate, Virgil Wilhite, and when I demanded their return told me to "get a lawyer."

18. A few days later I met with Boston, Massachusetts attorney Michael Flynn, who agreed to defend me against the


organization, which on April 22, 1982 published a second SP declare accusing me of eighteen "crimes, high crimes and suppressive acts," including, inter alia, promulgating false information about Hubbard and the organization. In the late spring and summer of 1982 I obtained from Omar Garrison with his permission some of the documents I had delivered to him while in the organization which I considered I would need to defend myself against the organization's charges in the SP declares and whatever actions its leaders would bring against me in the non-scientology courts. I sent these to Mr. Flynn, who was at that time, and for the next four and a half years, the most effective, prominent and attacked attorney combating Scientology, and to Contos and Bunch, a California law firm, which by then had agreed to be local counsel for me against the organization. Mr. Flynn represented approximately twenty individuals with damage claims, and was in communication with hundreds of people involved in opposition to or knowledgeable about Scientology. The organization filed the Armstrong I suit against me on August 2, 1982, and the Hubbard biography documents that I had sent to my lawyers were ordered by the Court to be deposited with the Clerk where they stayed until trial in the spring of 1984.

19. In August and September 1982 the organization employed a number of private investigators to spy on and harass my wife and me. During that period one of these investigators assaulted me bodily, and another struck my body with a car, and attempted to involve me in a freeway accident by getting in front of my car and slamming on his brakes and pulling alongside my car and swerving into my lane. The organization also attempted to get the Los Angeles Police Department to bring criminal charges


against me in connection with the Hubbard documents which had become the subject of the civil litigation in LA Superior Court.

20. I filed a cross-complaint for fraud and fair game in 1982 against various Scientology corporations which was severed from the underlying document case and was never tried because it "settled" in December 1986. The underlying document case was tried without a jury by Judge Paul G. Breckenridge, Jr., who rendered a decision on June 20, 1984, a true and correct copy of which is attached hereto as Exhibit [D]. This document, known around the world as the "Breckenridge decision," rebukes Scientology's fair game doctrine and other abuses. It was affirmed on appeal, Scientology v. Armstrong (1991), 232 Cal.App.3rd 1060, 283 Cal.Rptr. 917. Judge Breckenridge states:

"In addition to violating and abusing its own members civil rights, the organization over the years with its "Fair Game" doctrine has harassed and abused those persons not in the [organization] whom it perceives as enemies. The organization clearly is schizophrenic and paranoid, and this bizarre combination seems to be a reflection of its founder LRH. The evidence portrays a man who has been virtually a pathological liar when it comes to his history, background and achievements. The writings and documents in evidence additionally reflect his egoism, greed, avarice, lust for power, and vindictiveness and aggressiveness against persons perceived by him to be disloyal or hostile." (Ex.D, 8:18-9:4).

21. Between the 1984 Breckenridge decision and December, 1986 settlement, the organization's campaign against me included


at least these acts: attempted entrapment; illegal videotaping; breaking into my car and theft of personal writings and art; filing false criminal charges against me with the Los Angeles District Attorney; filing false criminal charges against me with the Boston office of the FBI; filing false declarations to bring contempt of court proceedings against me on three occasions; obtaining perjured affidavits from English private investigators, who had harassed me in London in 1984, which falsely accused me of distributing "sealed" documents; international dissemination of Scientology publications falsely accusing me of crimes, including crimes against humanity; culling and disseminating information from my supposedly confidential "auditing" (psychotherapy) file. I know that the attempted entrapment, illegal videotaping, and filing false charges with the LA DA all involved Eugene Ingram, who had been thrown out of the Los Angeles Police Department for allegedly pandering and taking payoffs from a drug dealer. In the fall of 1984 Mr. Ingram called me and threatened to "put a bullet between [my] eyes."

22. The circumstances leading up to and at the time of my signing of the December, 1986 " settlement agreement" make understandable why I would sign such a bizarre document. I had prevailed overwhelmingly in the defense side of Armstrong I. My cross-complaint against Scientology was set to go to trial in early 1987. Lawrence Wollersheim had in July, 1986, obtained a twenty-five million dollar jury verdict against Scientology, also in LA Superior Court. By December, 1986 I had weathered five years of fair game. Michael Flynn, my attorney and employer, who had represented me throughout Armstrong I, had been Scientology's fair game target for seven years. The organization had sued him


and/or his office more than a dozen times in various jurisdictions. The organization had "black PRed" him around the world; infiltrated his office; stolen documents; contacted and paid known criminals for statements falsely accusing him of crimes (for a glimpse, see, e.g., U.S. v. Kattar, 840 F.2d. 118); paid some of his former clients to execute false sworn statements attacking him; framed him with an attempt to cash a forged check on one of L. Ron Hubbard's bank accounts; and attempted to bring false criminal charges against him. He expressed in many ways an abiding concern that his family was at physical risk. Eugene Ingram was involved in and largely responsible, as Scientology's paid agent, for framing Mr. Flynn and attempting to have him charged criminally. Mr. Flynn several times made the statement to me, and publicly to hundreds of others, that he believed Scientology had attempted to have him killed by tampering with his private plane. He filed his own lawsuits against Scientology and Mr. Hubbard in response to the fair game attacks.

   23. During the years the organization carried out its war on Mr. Flynn, organization lawyers had communicated and met with him on a number of occasions regarding settling his and his clients' cases. I knew that such meetings occurred because I was one of those clients from early 1982 and I had worked for Mr. Flynn from September, 1985 through 1986 in his office in Boston. Around the beginning of December, 1986 Mr. Flynn called from Los Angeles, where he was meeting with Scientology's lawyers to say that a "global settlement" had been reached. He already had my agreement on a monetary figure for which I would settle my lawsuit. He was to be paid a lump sum which he was to divide between his clients and himself.


24. I have in the past waived my attorney-client privilege as to my conversations with Mr. Flynn at the time of and concerning the "global settlement," and I again waive that privilege as to those conversations. I have stated these facts in several declarations since 1990. On December 5, 1986 I was flown to Los Angeles, as were several other of Mr. Flynn's clients from various places, to participate in this settlement. Shortly after my arrival in LA I was shown a copy of the "settlement agreement" (identical in all important respects to Exhibit C hereto) and some other documents, which Mr. Flynn indicated I was to sign.

25. Upon reading the settlement agreement draft I was shocked and heartsick. I told Mr. Flynn that the condition of

"strict confidentiality and silence with respect to [my] experiences with the [organization]" (Ex. C, ¶7D), since it involved over seventeen years of my life, was impossible. I told him that the "liquidated damages" clause (Ex. C, ¶7D) was outrageous; that pursuant to the settlement agreement I would have to pay $50,000.00 if I told a doctor or psychologist about my experiences from those years; or if I put on a resume what positions I had held during my organization years. I said that if I went on a date and the woman of my dreams asked me where had I been all her life, I'd have to pay Scientology $50,000 if I dared to tell her. I told Mr. Flynn that the requirements of non-amenability to service of process (Ex. C, ¶7H) and non-cooperation with persons or organizations adverse to the organization (Ex. C, ¶¶7G, 10) were obstructive of justice. I told him that I felt that agreeing to leave the organization's appeal of the decision in Armstrong I and not respond to any


subsequent appeals (Ex. C, ¶4B) was unfair to the courts and all the people who had been helped by the decision. I told Mr. Flynn that an affidavit the organization was demanding that I sign along with the settlement agreement was false. The document stated, inter alia, that my disagreements with the organization had been with prior management and not with the then current leadership. In fact there had been no management change and I had the same disagreements with the organization's "fair game" policies and actions, which had continued without change up to the time of the settlement. I told Mr. Flynn that I was being asked to betray everything and everyone I had fought for against organization injustice. It was as if no more restrictive, insulting, mean spirited, impossible and immoral an "agreement" could have possibly been "negotiated" on my behalf.

26. In answer to my objections to the settlement agreement Mr. Flynn said that the silence and liquidated damages clauses, and anything which called for obstruction of justice were "not worth the paper they're printed on." He said the same thing a number of times and a number of ways; e.g., that "you cannot contract away your Constitutional rights;" that "the conditions are unenforceable." He said that he had advised the organization attorneys that those conditions in the settlement agreement were not worth the paper they were printed on, but that the organization, nevertheless, insisted on their inclusion in the settlement agreement and would not agree to any changes. He pointed out the clauses concerning my release of all claims against the organization to date and its release of all claims against me to date (Ex. ¶¶C, 1,4,5,6 and 8)and said that they were the essential elements of the settlement and "are what


they're paying you for."

27. Mr. Flynn also said that everyone was sick of the litigation and wanted to get on with their lives. He said that he was sick of the litigation, the threats to him and his family and wanted out. He said that as a part of the settlement he and all co-counsels had agreed to not become involved in organization-related litigation in the future. He expressed a deep concern that the courts in this country cannot deal with the organization and its lawyers and their contemptuous abuse of the justice system. He said that if I didn't sign the documents all I had to look forward to was more years of harassment and misery. One of Mr. Flynn's other clients, who was in the room with us during this discussion, yelled at me, accusing me of killing the settlement for everyone, and that everyone else had signed or would sign, and everyone else wanted the settlement. Mr. Flynn said that the organization would only settle with everyone together; otherwise there would be no settlement. He did agree to ask the organization to include a clause in my settlement agreement allowing me to keep my creative works relating to L. Ron Hubbard or the organization (Ex. C, ¶7L).

28. Mr. Flynn said that a major reason for the settlement's "global" form was to give the organization the opportunity to change its combative attitude and behavior by removing the threat he and his clients represented to it. He stated that the organization had promised that if we settled they would cease all fair game. He argued that the organization's willingness to pay us substantial sums of money, after its agents and attorneys had sworn for years to pay us "not one thin dime," was evidence of a philosophic shift within the organization. I argued that the


settlement agreement evidenced the unchanged philosophy of fair game, and that if the organization did not use the opportunity to transform its antisocial nature and actions toward its members, critics and society I would, a few years hence, because of my knowledge of organization fraud and fair game, be again embroiled in its litigation and targeted for extralegal attacks.

29. Regarding the affidavit the organization required that I sign, Mr. Flynn said that the "disagreement with prior management" could be rationalized as being a disagreement with L. Ron Hubbard, and since Mr. Hubbard had died in January 1986 it could be said that I no longer had that disagreement. Mr. Flynn said that the organization's attorneys had promised that the affidavit, which he said all the settling litigants were signing, would only be used by the organization if I began attacking it after the settlement, and since I had no intention of attacking the organization the affidavit would never see the light of day.

30. During my meeting with Mr. Flynn in Los Angeles I found myself facing a dilemma which I reasoned through in this way. If I refused to sign the settlement agreement and affidavit, all the other settling litigants, many of whom had been flown to Los Angeles in anticipation of a settlement, would be extremely disappointed and would continue to be subjected to organization harassment for an unknown period of time. I had been positioned in the settlement drama as a deal-breaker and would undoubtedly lose the support of some if not all of these litigants, several of whom were key witnesses in my case against the organization. Although I was certain that Mr. Flynn and my other lawyers would not refuse to represent me if I did not sign the documents I also knew that they all would view me as a deal-breaker and they would


be as disappointed as the other litigants in not ending the litigation they desperately wanted out of. The prospect of continuing the litigation with unhappy and unwilling attorneys on my side, even though my cross-complaint was set for trial within three months, was distressing. On the other hand, if I signed the documents, all my co-litigants, some of whom I knew to be in financial trouble, would be happy, the stress they felt would be reduced and they could get on with their lives. Mr. Flynn and the other lawyers would be happy and the threat to them and their families would be removed. The organization would have the opportunity they said they desired to clean up their act and start anew. I would have the opportunity to get on with the next phase of my life and the financial wherewithal to do so. I was also not unhappy to at that time not have to testify in all the litigation nor to respond to the media's frequent questions. If the organization continued its fair game practices toward me I sensed that I might be left to defend myself and I accepted that fact. So, armed with Mr. Flynn's advice that the conditions I found so offensive in the settlement agreement were not worth the paper they were printed on, and the knowledge that the organization's attorneys were also aware of that legal opinion, I put on a happy face and the following day went through the charade of a videotaped signing. I believe I was guided by God in making the legally ill-advised decision to sign Scientology's documents. This secret scheme to corrupt Justice is now seen as the evil it is in large part because of Scientology's insistence that Justice's corruption was its right.

31. It was my understanding and intention at the time of the settlement that I would honor in a sensible way the silence


and confidentiality conditions of the settlement agreement. I would not contact the media about Scientology, publish my Scientology history or file statements in court concerning Scientology. It was also my understanding that the organization had agreed to do likewise; i.e., it would not contact the media about me, publish my Scientology history or file statements in court concerning me. Although the "settlement agreement" did not specifically prohibit Scientology from communicating about me, it implied a reciprocality, and I knew that if it did communicate I would be free to respond. That Scientology would be able to say whatever it wanted about me to the media, in publications, to governments, and in judicial or administrative proceedings, and could judicially prosecute me if I responded was, at that time and in this country, inconceivable to me.

32. A few weeks after the "settlement" I was advised by a Los Angeles Times reporter that Scientology agents had delivered a stack of documents about me to the paper. Although shocked by this action, which was out of the blue because I had said or done nothing about Scientology after the "settlement," I did not respond. Following the settlement, and before I responded in any public way, Scientology subjected me to considerable fair game, which included filing affidavits falsely accusing me of crimes and of being an "agent provocateur of the United States government;" publishing distorted versions of my Scientology history; using documents which the organization had requested be sealed in Armstrong I to attack me; distributing dead agent packs of documents concerning me to the media; distributing copies of edited versions of the illegal videotapes of me to the media internationally; blackmail; and threatening me six times with


being sued if I responded to any attacks. Scientology also continued to subject other people to fair game, in violation of its promise through Mr. Flynn that it was ceasing all fair game activities. The person who in the fall of 1987 delivered documents concerning me and a doctored and edited copy of the 1984 illegal videotape of me to the London Sunday Times was Eugene Ingram.

33. For three years I attempted to live by the spirit of settlement, and, although threatened and saddened by Scientology's continuing attacks, did not respond, but had tried to live my life away from Scientology's war. I wrote, drew, ran, had remarkable ideas, and formed The Gerald Armstrong Corporation ("TGAC") with wonderful hopes and great expectations. In late 1989, however, after a series of threats from Scientology lawyer Lawrence Heller, following my being served with a deposition subpoena in the case of Bent Corydon v. Scientology, Los Angeles Superior Court No. C 694401, I concluded that I had to do something to defend myself. I saw that I could not avoid a confrontation with the organization, and that there was a need to correct what I knew was as an obstruction of justice, that the settlement contracts and Scientology's enforcement thereof were working in the legal arena. Mr. Heller threatened that if I testified about my knowledge of Hubbard and Scientology, even though I had been subpoenaed to testify, Scientology would consider such testimony a breach of the "contract" and would sue me.

34. I researched my rights and responsibilities and concluded that I had a duty to oppose known obstruction of justice. I also learned at that time that Scientology had been


able to maintain an appeal from the Breckenridge decision in the California Court of Appeal and had just then filed its opening brief. I therefore petitioned that Court to be able to file a response. My filings in the Court of Appeal in 1990 included a declaration detailing and documenting Scientology's post-settlement torts and violations, and a declaration detailing the circumstances at the time of the 1986 settlement. The Court of Appeal granted my petition , I filed a respondent's brief, and in July, 1991 the Court affirmed the Breckenridge decision. Following the California Supreme Court's denial of review, Scientology filed a motion in the Court of Appeal to seal the record on appeal. I opposed the motion, and the Court of Appeal denied it. The complete trial transcript, which contains ten days of my testimony about my Scientology experiences up to 1984, is a public document.

35. In August, 1990 I was greatly moved by the buildup toward war in the Middle East, and the general condition of man. I prayed to God for guidance as to what I should do, and received the word: "Keep nothing. Give what you have to the poor. Take only what you need." I gave my possessions to those whom I believed had a need for them as put in my heart by God, forgave debts owed to me, and determined to go where God would have me go and do what God would have me do; which I believed was to help where my help was asked for. Although these decisions had nothing to do with Scientology, the organization has made them relevant in the legal arena by suing me and three of my friends, falsely charging that my giving away my things were "fraudulent conveyances" to make myself "judgment proof" so I could breach its "settlement agreement." For the next year after my


renunciation God had me, among other things, offer myself to resolve the Middle East conflict, do some house painting and carpentry work, deal with the pending appeal, attempt to correct Scientology's subversion of the legal system, agree to help the victims of Scientology who asked for my help, and offer myself to resolve the Scientology conflict in which I had been drawn by its attacks.

36. Scientology's fair game attacks on me following my responding in its appeal of the Breckenridge decision include, but are not limited to, secretly videotaping me; suing me and TGAC (pronounced "Teegeeack") four times (Marin Superior Court Case No. 152229, transferred to Los Angeles Superior Court and given No. BC 052395 ("Armstrong II"), Los Angeles Superior Court Case No. BC 084642 ("Armstrong III"), Marin Superior Court Case No. 157680 ("Armstrong IV," the "fraudulent conveyance" case), United States Bankruptcy Court for the Northern District of California Case No. 95-10911 aj, Adv. No. 95-1164 aj ("ArmstrongV"); Armstrong II, III and IV were consolidated into Marin SC No. 157680); attempting to have me jailed for contempt of court based on Scientology's misrepresentation of my actions and its own manufactured charges; filing declarations in various courts containing false charges, and using the "settlement agreement" to prevent me from responding or punish me for responding; using Eugene Ingram to spread the false rumor in 1992 that I have AIDS; forcing me into bankruptcy; attempting to seize my artwork, and personal and intellectual property through judicial means based on false charges; disseminating to the media packs of black PR which provide Scientology's false version of my experiences, including the lies that I testified falsely at trial in 1984;


that I have "adopted a degraded lifestyle;" that I am connected to a referral agency for kidnapping; that my defense in the 1984 trial was a sham and a fraud; that the Los Angeles Police Department authorized the illegal 1984 videotaping; that I wanted to plant fabricated documents in Scientology files and tell the IRS to conduct a raid; that I wanted to plunder Scientology for my own financial gain; that I never intended to stick to the terms of the "settlement contract;" that my motives are money and power; that I was incompetent as a researcher; that I perjured myself about surrendering documents to the court; that I wanted to orchestrate a coup in which members of the US government would wrest control of Scientology; publishing black propaganda about me without stating its source which provide Scientology's false version of my experiences including the lies that I was formerly a heavy drug pusher; that a Marin Independent Journal photo showed me in the nude; that I am psychotic and live in a delusory world; charging falsely in a letter to the press that I had distinguished myself by posing naked in a newspaper; attempting to cause me trouble with the IRS by writing black propaganda letters about me; distributing packs of black propaganda which attacked my lawyer Ford Greene, and Judge Breckenridge.

37. I worked with attorney Greene from August, 1991 through December, 1995, except for about three weeks in April, 1995. Throughout that period Scientology attempted overtly through misuse of the courts and covertly through its Office of Special Affairs ("OSA"), the organization's intelligence arm, along with other operatives, to prevent me from working with Mr. Greene and from defending myself. Scientology employed a covert operative, Garry Scarff, whom it had infiltrated into Mr. Greene's office,


to develop a black PR "attack line" that Mr. Greene and I were involved in a homosexual relationship. Scientology has subjected Mr. Greene to years of fair game, which included having Scarff, while in his office, steal his office records and cause trouble; concocting a plot with Scarff to have him killed; having Scarff execute false declarations about Mr. Greene; filing five spurious bar complaints against him; operating at least two of his clients, Richard and Vicki Aznaran, as Scientology's own agents, and paying them to execute false declarations against Mr. Greene and breach their contract with him. Scientology was able to achieve one of its desired goals with the Thomas order, Ex. A, which made my working with Mr. Greene threatening and virtually impossible. I have been denied two other good jobs in the past year because of my relationship to the Scientology organization and the threat that goes with it. I have within the past week learned from Mr. Greene that his office was recently burglarized and my office file stolen along with other important legal files. Eugene Ingram has been involved in the attacks on Mr. Greene, has harassed his friends, and sought by " legal" and illegal means to prevent him from effectively litigating against Scientology.

38. Throughout its post-settlement judicial attacks on me Scientology has proclaimed that by the "settlement agreement" it sought peace. Scientology also interprets the "agreement" to mean that it can say whatever it wants about me, no matter how false, obnoxious or evil and that I may not respond. The organization has indeed said whatever it wanted to about me, falsely accusing me of crimes and attacking my character and credibility. Scientology claims that if I do respond in any way I am liable for $50,000 in liquidated damages, and may be jailed.


Scientology, under David Miscavige, has filed bogus lawsuits and been able to get Marin Superior Court Judge Gary W. Thomas for bogus reasons to give them an unreasonable interpretation of the agreement and an unreasonable judgment. Judge Thomas has stated that essentially Scientology may say whatever it wants and I may not respond. Because of, inter alia, what that kind of decision and reasoning portends for Lady Justice, and because the silence of bells too cannot be unrung, I have not succumbed quietly.

39. Through the decade of Scientology's legal attacks on me after the December, 1986 "settlement," it has intimidated Mr. Flynn into not coming forward to assist me. He was not only my attorney, he was my good friend. He now says that the contract is evil, that Scientology is evil and he wants to help me. He also says that he signed a "contract" with Scientology, which I was unaware of at the time of the "settlement," which specifically prevents him from assisting me. While acknowledging that this "contract" is illegal, he says that he knows that his life will be ruined even more than it has been by Scientology if he comes forward to help.

40. I believe that Scientology's interpretation of the "settlement agreement," to which Judge Thomas has added the authority of the California courts, is unconscionable and unamerican. Because there are dozens of these "contracts" among first hand witnesses to Scientology's criminal and tortious practices, and because of Scientology's fair game use of the "settlement agreement" against me, I believe that a terrible injustice is being abetted by our courts, which should be opposed with all strength. In my opinion, that one party to a settlement contract, which is supposed to be essentially a peace accord, is


able to continue to shoot at the other party, who is wounded, has been disarmed and is not being allowed to defend himself in any way, is not peace at all but a demonic hunting trip. The "settlement agreement," and now the judgment enforcing it, are in this "civilized society," licenses for hunting humans.

41. I was paid in settlement by Scientology for its years of psychological cruelty, threat and stalking; i.e., fair game. Scientology's leaders did not learn their lesson but continued the cruelty, threat and stalking of a person already psychologically hurt and altered beyond belief by the actions they promised to cease. I performed my part of the 1986 settlement. I dismissed my cross- complaint, released to Scientology all evidence from my case, removed myself from controversy, and gave Scientology the time and freedom it said it wanted to cease fair game. Scientology's leaders, knowing that they had compromised and removed my attorney, failed to perform their part of the settlement, but continued fair game against me after they had psychologically wounded me and, they thought, rendered me defenseless.

42. In 1991 I became a Christian. I had, in the years after leaving Scientology, come to recognize that I was guided by God, and I sought to be guided in all circumstances in which I found myself. Once its adherents become sufficiently brainwashed, Scientology does not permit them to believe in God, labels and treats anyone who believes in God as "psychotic," and enforces the satanic idea that God is an "implant," a false idea installed by pain and electronics in man's mind to enslave him. Scientology also teaches that Jesus Christ, the whole Gospel story, and Heaven are implants designed to enslave man, and that


only Scientology has the way to free mankind from this enslavement.

43. Scientology promotes to Christians and non- Christians that it is compatible with Christianity, that it holds the Judeo-Christian Bible as a holy work, and that it has no argument with the belief that Jesus Christ was the Savior of Mankind and Son of God. Scientology has distributed promotional materials containing these representations to every member of Congress, to libraries, to the media, to educators, to judges, and to people of influence across this country. Scientology withholds from the public its actual enforced beliefs about God, Christ, Heaven and the Bible. I believe this is religious fraud, and dangerous to everyone lured into Scientology, those already held by its brainwashing system, and society itself. I also believe that Scientology's "creed" is a religious fraud because Scientology, under Hubbard's and Miscavige's control, has never acted in accord with it. Scientology systematically abuses its members' civil rights, and seeks to destroy the same civil rights of its non-Scientologist "enemies."

44. Scientology promotes actively and aggressively and uses the public postal system, public forums and public media for its promotions. Scientology is a public figure. It uses its resources to affect legislation and to violate people's civil rights. Its efforts to judicially and extra-judicially silence and destroy me are clear examples. I believe that this is not a legal purpose and not a purpose for which tax-exempt funds can legally be used. I see that Scientology tricks and extorts huge sums of money from people it lures into its system for something of no value. This money will be used to pay lawyers to attack


the same people and those who seek to bring to light or curtail the abuse. I have proof that Scientology obtained its tax-exempt status in 1993 by illegal means. I believe that the Internal Revenue Service and the United States government agencies responsible were derelict in their duties in granting such tax exempt status.

45. The documents attached hereto as Exhibits E, F and G show Scientology's use of the "settlement agreement" to skew (and skewer) justice. Exhibit [E] is a true and correct copy of a declaration executed February 8, 1994 by organization leader David Miscavige and filed in the case of Scientology v. Fishman and Geertz, US District Court for the Central District of California, Case No. CV 91-6426 HLH(Tx). Mr. Miscavige devotes a paragraph to attacking and lying about me, although I had never up to that time filed any statement in the Fishman case. (Ex. E, 31:22- 32:14) In response to this attack and to provide the truth underlying Mr. Miscavige's false charges I filed in Fishman a declaration executed February 22, 1994, a true and correct copy of which, along with true and correct copies of the exhibits thereto, is attached hereto as Exhibit [F]. Shortly thereafter Scientology moved to seal certain documents in the Fishman court file, one of which was my February 22 declaration. In response and in opposition to this motion I wrote and filed a declaration executed April 21, 1994, a true and correct copy of which, without the exhibits thereto, is attached hereto as Exhibit [G]. Scientology sued me for these declarations, charging that they were "breaches" of its "settlement agreement," and claiming $50,000 liquidated damages for each. My "voluntary ssistance" to defendants Fishman and Geertz by way of these declarations is


referred to in the Thomas order at Ex. A, 4:8-11. Correcting of the Miscavige lies and preventing my own words from being sealed was impossible "involuntarily" because discovery was already closed in the Fishman case. Even if discovery was still open, there was not sufficient time to go through the ritual of being served, opposing Scientology's motions to prevent the deposition from going forward, combating Scientology's obstructionist lawyers in deposition, and waiting for the deposition transcript. In my opinion, Mr. Ward is in a similar position: even if he could afford to pay a court reporter, there is not time enough to obtain the needed testimony before it is needed. For this reason alone I believe non-assistance "contracts" such as those Scientology uses must be ruled illegal.

46. That Scientology will move to block the depositions of people who signed its "settlement agreements" is shown by Scientology's "motion .. to delay or prevent the taking of certain third party depositions," a true and correct copy of which is attached hereto as Exhibit [H]. Scientology filed this motion in the Corydon litigation after I was served in the case with a deposition subpoena. The motion is based on a declaration by Scientology attorney Lawrence Heller executed November 1, 1989, a true and correct copy of which is also attached hereto as part of Exhibit H. In this declaration Mr. Heller states that "The non-disclosure obligations were a key part of the settlement agreements insisted upon by all parties involved." (Ex. H, 9:5-7) Mr. Heller also states in the memorandum of points and authorities: "One of the key ingredients to completeing these settlements, insisted upon by all parties involved was strict confidentiality respecting: ... any knowledge possessed by the


Scientology entities concerning those staff members or parishioners." (Ex. H, 4:9-14) Mr. Heller was of course lying, because Scientology had by then disseminated mountains of post-settlement black PR about me possessed by the organization. He was also lying about the reciprocality of the non-disclosure conditions because Scientology enforced its "settlement agreement" with me on that basis of its being able to say whatever it wanted about me but I must remain silent. Judge Thomas's refusal to deal with or even acknowledge attorney Heller's lies and Scientology's inconsistent statements concerning reciprocality, even though these were carefully pointed out to him in my papers filed in the cases before him, I believe is an indicator of Scientology's corruption of the judicial process.

47. That Scientology will also subvert our courts' power to prosecute "contempt" is shown in its "application for order to show cause why Gerald Armstrong should not be held in contempt," filed December 31, 1992 in Armstrong II. A true and correct copy of the application and Scientology's supporting documents is attached hereto as Exhibit [I]. Scientology filed another application for an OSC re contempt shortly after this one, charging that my providing a declaration to Lawrence Wollersheim in the case of Scientology v. Wollersheim, Los Angeles Superior Court Case No. BC 074815, was a violation of its "injunction." Scientology's charges were either misrepresentations of my actions or completely manufactured. Ultimately Judge Diane Wayne discharged all of Scientology's contempt charges in a ruling dated July 28, 1994, a true and correct copy of which is attached hereto as Exhibit [J]. I do not believe I will receive equally


fair treatment from Judge Thomas, and I am at great risk of Scientology being successful before him in its pressing to have me jailed. I wrote a declaration in opposition to Scientology's contempt charges, and the organization deemed that declaration itself a violation of the "settlement agreement." I do not have immediate access to that declaration, and many of my legal papers, but I will be able to provide it and any other documents in the near future if requested. The documents I am attaching as exhibits to this declaration are a small fraction of the materials I have which show Scientology's malevolent side and its dedication to and employment of fair game.

48. Attached hereto as Exhibit [K] is a true and correct copy of an article from the Boston Globe dated November 24, 1979 concerning Scientology's fair gaming of writer Paulette Cooper, and mentioning other organization intelligence ops.

49. Attached hereto as Exhibit [L] is a true and correct copy of a series of articles from the Oregonian dated from March 28, 1985 through May 24, 1985 covering the trial of Julie Christofferson against Scientology in Portland, Oregon. The April 5, 1985 article contains the statement concerning the illegally obtained videotapes of me: "'I think they are devastating, devastating against the church,' Multnomah Circuit Judge Donald H. Londer said." The May 18, 1985 article announces the jury's award of thirty-nine million dollars to Ms. Christofferson.

50. Attached hereto as Exhibit [M] is a true and correct copy of an article from the Los Angeles Times announcing Judge Londer's declaring a mistrial, a month after the jury rendered its verdict.


51. Attached hereto as Exhibit [N] is a true and correct copy of a series of articles from the Toronto Star and the Toronto Sun dated from March 12, 1992 through April 30, 1992 covering a $1.6 million damage award to Crown Prosecutor Casey Hill whom Scientology and its lawyers libeled, and the trial of Scientology in Toronto, Canada for spying and theft.

52. Attached hereto as Exhibit [O] is a true and correct copy of an article from the Denver Post dated November 23, 1996 concerning the conviction of the head of Scientology in Lyon, France for subjecting a man to "psychological torture" resulting in his suicide.

53. Attached hereto as Exhibit [P] is a true and correct copy of an article from the San Francisco Chronicle dated December 26, 1996 concerning Germany's efforts to control Scientology's abuses and Scientology's attack on Germany.

54. These articles, which are but a small fraction of the press around the world critical of Scientology, also support the invalidation of the Scientology's "settlement agreements" and the Thomas order. It is entirely wrong that anyone be denied participation in a public controversy of this magnitude, a public controversy concerning national sovereignty and national security decisions.

55. It is also wrong, and I believe constitutionally impermissible, to deny anyone freedom of religion by "contract" or court order. The Thomas order prohibits me from "discussing ... Scientology, the Church, and/or any of the Beneficiaries;" (Ex. A, 8:14-16) If such a prohibition is legal concerning Scientology, a parallel prohibition would be legal concerning, for example, Christianity, God, and any religious experience of


any kind. The idea that this country's courts can give a "church" $50,000 in liquidated damages and send someone to jail for his discussing God or Christ or the Holy Scriptures, is of course absurd. Who but evil itself would hatch such an idea? Scientology's "settlement agreement," its efforts to enforce, and the Thomas order are no less absurd, and no less evil's idea. Suppression of critics of a religion through judicial means is a violation of the Constitution's "Establishment Clause," and the Religious Freedom Restoration Act of 1993. Michael Flynn did not have my permission to sell Scientology my freedom of religion (nor any of the other personal freedoms I possessed and enjoyed before the "settlement"), and even if I had given him such permission he could not sell it. It cannot be sold. Scientology couldn't buy it. It cannot be bought. Scientology claims it purchased my freedom of religion, in fact claims that it paid me eight hundred thousand dollars for it, but it could not have. If it paid $800,000.00 for something it couldn't buy, receive or possess it paid way too much. In reality, and I would think happily for Scientology, it received from me the dismissal of my cross-complaint, my accumulated evidence of its fraud and criminality, and my sincere efforts to let there be peace. Thus it got a terrific deal, and its whining that I wouldn't sell what it couldn't buy is silly.

56. Freedom of religion without freedom to discuss religion and religious experience is impossible. Scientology insists that the world accept that it is a religion. It asserts in its "bona fides," indeed in the submissions upon which it was able to get the US Government to give it tax-empt status, that it is organized solely for religious purposes. The experiences of its


members inside and in relationship to the organization, its founder, its "scriptures," its practices and its other members must therefore be religious experiences. In my opinion, as long as Scientology maintains that it is a religion it cannot legally prohibit, by judicial means in this country's courts, anyone from discussing anything about it. In my opinion, since Scientology insists on binding its members with "non-disclosure bonds" and similar "contracts," and binding its former members or targeted "enemies" with "settlement agreements" like Exhibit C hereto, it cannot be a religion; i.e., it cannot have it both ways.

57. In my opinion, the exposing or dissemination of Scientology's "sacred scriptures," which is at issue in the Ward, Henson and Erlich cases, as well as in the Lerma and Factnet cases, is an analogous situation in which the same greater principle of religious freedom applies. An entity which claims to have secret writings, which people to see must pay and agree to not discuss, cannot actually be a religion, because such a policy on its face restricts or prohibits religious expression. Such an entity can be a "secret-selling company," or some such, in competition with other secret-selling companies, as long as it does not try to claim that the secrets it sells are "religious" secrets. Practically speaking, the only time this would become an issue is if an entity claiming to be a religion attempted to judicially prohibit the publication of its religious secrets or judicially punish their publishers. Obviously people have the normal secrets that normal people have, and people talk about them and keep them or not, and so forth. A real religion would have no reason to prevent the publication of its scriptures, and it would possess no "secret scriptures." In my opinion, whoever


has published Scientology's "secret scriptures" has in reality only been engaging in religious expression. In my opinion this kind of expression is an expected, logical response to Scientology's efforts to corrupt the meaning of religion to "sanctify" its antisocial and dangerous mind set and criminal activities. It is expression which cannot legally be prohibited or punished by judicial process.

58. In my observation, Mr. Ward, Mr.Wollersheim, Mr. Henson, Mr. Erlich, Mr. Lerma and Mr. Penny (hereinafter, "WWHELP") are in general agreement that Scientology is not a sincere, and hence real, religion but is a criminal cult engaged in harmful practices. In my opinion, if WWHELP are correct in their assessment, and if they did expose or publish Scientology's secret documents, they were and are completely justified in having done so. It goes without saying that criminal cults, or any criminal enterprises for that matter, are against public policy. It is certainly conceivable that writings which direct criminal cult members to think a certain way and perform certain acts in order to rise within the criminal cult's hierarchy, or become more criminal, are also against public policy. In my opinion a reasonable person who has been presented with the facts about Scientology that each of the alleged publishers possessed at the time the publications were made would have believed that the prosecution of anyone pursuant to trade secret or copyright law for the publication of such writings is itself against public policy. Thus Scientology's actual nature is relevant to WWHELP's defenses. If Scientology is a religion, then WWHELP are justified in their religious expression. In my opinion, for Scientology to now "become" a religion, among the other things it


must do, it must cease its judicial persecution of anyone for his religious expression, even if that be criticism, publication or sworn testimony. Scientology must otherwise, in my opinion, be seen as electing to remain a criminal cult, and must in these matters have our courts' ears shut to it, in limine.

59. This Court stated in its order dated January 6, 1997 filed in the Erlich case:

"The relevant inquiry is whether the documents for which trade secret protection is sought are "'generally known' to the relevant people -- the potential 'competitors' of the Church." [site] Nevertheless, defendant has not established the extent to which the specific processes and instructions contained in the works are known generally or to potential competitors.
"How to identify "potential competitors" is a difficult question. However, members of the newsgroup "alt.religion.scientology" might be considered as such." (Order, 21:10-14;n.17).

The identification of Scientology's "potential competitors" is actually not a difficult question. In accordance with a long line of US Supreme Court cases touching on religious matters, a court's attempting to answer such a question would, however, be impermissible. It is made "difficult" only because our courts do not generally, aside from rare anomalies such as "natural disasters," permit themselves to ascribe causation in human affairs to God. The actions of Scientology, calling itself a religion and prosecuting religious expression in secular courts, now make answering this question in these courts possible and permissible. In my opinion, Scientology's actual "competitors"


are those whom God guides, those through whom He works to carry out His purposes.

60. In the "religious realm," God's working in the lives of people, although, to those who understand it, infinitely more wonderful than any other conceivable possibility, is simply what's true, at least for someone. This nation's courts have dealt with this truth by insisting that within the cases over which they preside the truth or falsity of religious beliefs will not be questioned; in this case, whether God indeed works in people's lives, and specifically whether God's guidance resulted in the exposing or publication of Scientology's "secret scriptures."

61. The guided come from any religion and from no religion They include those who seek God's guidance and those who don't seek His guidance, and may not even know or care that it is available. Some people may know they're called to do God's work, and don't do it. Some may not know they're called but do His work anyway. This is easily understandable because God has given everyone a conscience and written His Laws on everyone's heart, whether they know it or accept it or not. It is also easily understandable that the guided would be Scientology's natural "competitors" because Scientology has made a religion of nonguidance; and religion is a realm in which God observably has never let nonguidance triumph. Although man may attempt to keep God out of his other realms, he cannot keep God out of religion, because in this world it is His Realm.

62. Scientology does not acknowledge God's guidance, in fact teaches, despite its public relations to the contrary, that God does not exist. In his bulletin dated May 11, 1963 entitled


"Routine 3 Heaven," a true and correct copy of which is attached hereto as Exhibit [Q], L. Ron Hubbard writes that Heaven, God and Christ are "implants," electronic mechanisms to entrap and enslave mankind. These "religious" assertions are of course blasphemous. He writes moreover about the scientific nature of this "knowledge:"

"This HCO Bulletin is based on over a thousand hours of research auditing, analyzing the facsimiles of the reactive mind, and with the help of a Mark V Electrometer. It is scientific research and is not in any way based upon the mere opinion of the researcher. This HCO Bulletin is not the result of the belief or beliefs of anyone. Scientology data reflects long, arduous and painstaking research over a period of some thirty years into the nature of Man, the mind, the human spirit and its relationship to the physical universe. The data and phenomena discovered in Scientology is common to all minds and all men and can be demonstrated on anyone. Truth does not require belief to be true any more than water requires anyone's permission to run downhill. The data is itself and can be duplicated by any honest researcher or practitioner." (Ex. Q, at p. 4)

"Routine 3 Heaven" is considered by Scientology as part of its "confidential Church scriptures which are protected trade secrets." I possessed this bulletin inside the organization, legally possess it now, and know personally at least a dozen other people who now possess it.

63. In his bulletin dated September 23, 1968 entitled


"Resistive Cases Former Therapy," a true and correct copy of which is attached hereto as Exhibit [R], Mr. Hubbard writes that "the Christian Churches [ ] uses implanting." He calls them "gangsters" who "invented Christ (who comes from the crucifixion in R6 75m years ago)(Hubbard's parens.) and implanted their way to "power"." (Ex. R. at p. 2). This is also one of Scientology's "secret scriptures," which I and many other people legally possess. It, like the rest of the organization's "secret scriptures," is an attack on Christianity, and blasphemous.

64. Scientology has its salvation "plan, " its goal to "clear the planet." It charges, even extorts, terrible sums of money, and lies to, cheats and bullies its adherents and targeted opposition. Its guiding principle is fair game, its doctrine of opportunistic hatred, pursuant to which it uses the law to harass its targets. God's plan on the other hand is free to everyone. He guides people to tell the truth and cheat and bully no one, but stand up to cheats and bullies, and stand up for their targets. Scientology's leaders and God and His guided are "competitors" for human souls. Scientology seeks to enslave souls, while God seeks only their freedom. Other enslavers of the soul work through other cons appealing to greed, lust, fear, evil and the like. They all lie. No one is guided by God to bind human souls with "contracts" or threats which limit their expression. No one is guided by God to hate, cheat or bully, or to use the law to harass. God's guidance is wisdom. Scientology's guidance is stupidity; hence dangerous. The exposing of dangerous cults masquerading as religions, and other enslavers, is a Biblically-blessed work of the guided. Bringing Scientology's actual nature, a facet of which is reflected in its


"secret scriptures," to light has arisen at this time because of a certain imminence. The global nature of Scientology's threat to religion, and its menace to the minds of God's children at this time are observable factors. It is altogether understandable that God would reach out through those who are available for His work in the realm of religion. WWHELP have played God-given rolls in bringing Scientology's fraud and dangers to light, and they are a part of those God guides to such religious expression. Some people testify, some picket, some encourage, some pray, some post their stories to ars. These very cool spirits may or may not believe, sense or know they are guided by God. One might think Christians would be the people most willing to speak out about Scientology and expose its "secret scriptures," because in the realm of religion the organization theologically is antichristian. I have no reason to believe that any of WWHELP consider themselves Christians. WWHELP in fact may have thought they exposed Scientology's "secret scriptures," if they indeed did, for other reasons; e.g., that they showed it to be a criminal cult; that they are evidence of practicing medicine without a license; that the exposure might save someone from paying the criminal cult three hundred sixty thousand dollars to get to see them. In my opinion, they have done God's work. Supporting that opinion is that fact that they published whatever they did without any intent to gain monetarily thereby. A prophet brings God's message to His children, and cannot be silenced by our courts, even if he is a Prophet to Scientologists.

65. Scientology claims to be prosecuting WWHELP for allegedly publishing its "secret scriptures," which includes the


"OT materials," and the "NOTS materials." To accomplish its raids and bring and maintain its lawsuits the organization has asserted that the OT and NOTS materials had been kept secret, and were not generally known except by its own adherents. This is false. I have possessed a copy of the OT materials for many years, and I know others who possessed these materials long before any of the internet publications. During the Armstrong I litigation I possessed a copy of the complete set of NOTS materials, and I know several other people who possessed them long before any were published on the internet. At the time of the Armstrong I "settlement" I delivered my copy of the NOTS materials to the Scientology organization. This copy should be available to WWHELP through discovery in their cases. In my opinion, Scientology's leaders have not brought these cases to protect the "secret scriptures," because they are not secret, but have used the law of trade secret and copyrights as an opportunity to harass available "targets," and thus send a brutal message to intimidate anyone whom God might call to stand up and speak free.

66. Each of the WWHELP cases is being prosecuted by Scientology entity RTC, which claims to own the "religion's" marks, trade secrets and copyrighted materials. RTC, operated by David Miscavige, is able to "legally" control the " religion, " its operations, personnel, communication lines, finances, lawyers and agents because of this claimed ownership. In my opinion RTC did not obtain this claimed ownership by legal means, and now maintains such illegally ownership to the detriment of the practitioners of the "religion" and society at large. It is my understanding that David Miscavige notarized the signature of L.


Ron Hubbard near the time of his alleged death in 1986 on a document which transferred Mr. Hubbard's ownership of certain rights and/or marks from himself to RTC. While on board the "Apollo" during 1972 through 1974 I was required on a number of occasions to have Mr. Hubbard's signature notarized on various documents. There were a couple of notaries in Portugal I got to know who would verify the signature by comparison with a signature in their signature book. There were times when I took documents to these notaries which were not signed by Mr. Hubbard, but by Joyce Popham, who could sign his signature extremely well. Two of the documents signed by Ms. Popham were for the registration of the marks "Dianetics" and"Scientology." The forging of signatures or obtaining false notarizations is not unreasonable in Scientology affairs. There is as well the more serious question of Mr. Hubbard's actually not owing or possessing the rights RTC says it acquired from him.

67. Attached hereto as Exhibit [S] is a true and correct copy of three documents I received in late November, 1996 from Craig Branch of the Watchman Fellowship, a Christian research and apologetics organization and publisher. The first document is an undated letter to me from Mr. Branch. The second is a letter dated October 21, 1996 from Cathy Norman of Scientology's Office of Special Affairs in Austin, Texas. The third document is black PR on me in the form of a standard "DA document." It repeats the same lies David Miscavige put in his declaration (Ex. E). See, e.g., Ex. S, DA Doc, at p. 4 where Scientology asserts that "the Church obtained permission from the Los Angeles Police Department to conduct undercover surveillance of Armstrong, and compare with Ex. F, and the attached public announcement of then LAPD Chief


Daryl Gates. According to Scientology I cannot respond to correct the lies in this latest example of Scientology's black PR to reach me, in this case sent to a prominent person in the Christian community. Scientology is attempting with this sort of attack, coupled with its "non-disclosure" contracts and orders, its glossy PR, legal triumphs, etc. to rewrite history. I believe Scientology's efforts to rewrite history are dangerous, and my silence only abets the threat. In my opinion, Scientology can never rewrite history, and it is well advised to give up the effort and instead through honest change become the honest organization it now tries dishonestly to get the world to believe it is.

68. On January 23, 1997 I received in the mail from Grady Ward a subpoena, a true and correct copy of which is attached hereto as Exhibit [T], for production of documents in his case.

69. On January 24 I received from attorney Andrew H. Wilson a fax letter, a true and correct copy of which is attached hereto as Exhibit [U], threatening prosecution in Armstrong IV if I provide documents to Mr. Ward pursuant to his subpoena. This letter is frightening to me, and supports why I am sending this declaration directly to the Court, and why the "settlement agreement" and the Thomas order are illegal. Mr. Ward does not have the time to wait for my testimony until Scientology's motion for protective order is heard before he must file this testimony. In my opinion, that is precisely why Mr. Wilson has sent his threat letter. Scientology already enjoys a terribly uneven playing field in its cases against WWHELP, especially against Mr. Ward and Mr. Henson, who are proceeding unfinanced and undefended by lawyers. We're kindred souls. Scientology spends millions on


lawyers and more millions on private investigators. Its history of attacks on judges and efforts to compromise judges was known to me inside the organization, and I have learned more about this evil since leaving. Scientology's personnel are trained to lie, and its lawyers paid to lie. It has a policy and history of destruction of evidence (See, e.g., Ex. D). It seizes every advantage our country's laws confer on religions and does not perform its responsibilities as a religion. It keeps witnesses with material evidence bound and intimidated by illegal "non-assistance" contracts and other threats. Other people who have testimony regarding Scientology's nature, structure, history, "scriptures," and practices, who I know or have been so informed, to also be bound by Scientology's "contracts," include, at least: Laurel Sullivan, William Franks, Howard Schomer, Martin Samuels, Michael Flynn, Esq., Julia Dragojevic, Esq., Garry P. McMurry, Esq., Gabe Cazares, Bent Corydon, Michael Douglas, Kima Douglas, Nancy Dincalci, Edward Walters, Julie Christofferson, Nancy McLean, John McLean, Warren Friske, Robert Dardano, Tonja Burden, Margery Wakefield, Paulette Cooper, David Mayo. In my opinion, Scientology steps so brazenly into court and sues so wantonly because it believes it has so many people bound to silence that it can lie with impunity.

70. Mr. Ward, and indeed all of WWHELP, should be able to freely obtain the testimony of anyone willing to testify on their behalf, or by subpoena anyone unwilling. They should be able to obtain the assistance of any expert witness they believe can help. Because Scientology has so distorted the floor of the legal arena I am moved to seek guidance in how to help. No person, seeking and knowing God's guidance, would not help. I


have a personal interest in the outcome of all of Scientology's cases, because an outcome favorable to the organization will be used to attack me and my friends.

 71. If it is within this Court's power, and I believe it is, I ask that it issue an order prohibiting Scientology from interfering with Mr. Ward's, Mr. Henson's and Mr. Erlich's witnesses, including me, and an order to Scientology to release me from its "contract" and the Thomas order so that I am free to assist these defendants in their cases.

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 January 26, 1997


Exhibit [A]

Exhibit [B]

Exhibit [C]
Mutual Release of All Claims and Settlement Agreement

Exhibit [D]
Breckenridge Decision

Exhibit [E]
David Miscavige Declaration 02-08-1994

Exhibit [F]
Armstrong Declaration 02-22-1994

Exhibit [G]
Armstrong Declaration 04-21-1994

Exhibit [H]
Notice of Motion and Motion of Defendant Author Services, Inc. to Delay or Prevent the Taking of Third Party Depositions by Plaintiff (Corydon)

Exhibit [I]
Application for OSC re Contempt 12-31-1992

Exhibit [J]
Judge Diane Wayne Ruling 07-28-1994

Exhibit [K]
Article from the Boston Globe 11-24-1979

Exhibit [L]
Series of articles from The Oregonian 03-28-1985 through 05-24-1985

Exhibit [M]
Los Angeles Times article re: Judge Londer's declares mistrial in Christofferson

Exhibit [N]
Series of articles from Toronto Star and the Toronto Sun 03-12-1992 through 04- 30-1992 re $1.6 million damage award to Crown Prosector Casey Hill

Exhibit [O]
Denver Post article 11-23-1996 re: conviction of the head of Scientology in Lyon, France

Exhibit [P]
San Francisco Chronicle article 12-26-1996 re: Germany's efforts to control Scientology's abuses

Exhibit [Q]
HCO Bulletin 11 May, 1963 ROUTINE 3 HEAVEN © 1963 L. Ron Hubbard [Excerpt]

Exhibit [R]
HCO Bulletin 23 September 1968 RESISTIVE CASES FORMER THERAPY © 1968 L. Ron Hubbard

Exhibit [S]
Three documents received November 1996 from Craig Branch:
1) Undated letter to Armstrong from Mr. Branch.
2) Letter 10-21-1996 from Cathy Norman, OSA Austin, TX.
3) Black PR "DA document"

Exhibit [T]
Subpoena from Grady Ward rec'd 01-23-1997

Exhibit [U]
Wilson Letter 01-24-1997