GREENE, O'REILLY, BROILLET, PAUL, SIMON,
MCMILLAN, WHEELER & ROSENBERG
LAWYERS
LOS ANGELES OFFICE
816 SOUTH FIGUEROA STREET
LOS ANGELES, CALIFORNIA 90017-2516
(213) 482-1122
(213) 482-1350

Attorneys for Plaintiff

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

I, GERALD ARMSTRONG, being duly sworn, state the following from my own personal knowledge:

1. In September of 1980, I was a staff member of the CHURCH OF SCIENTOLOGY OF CALIFORNIA. My superior was Laurel Sullivan, and during that time I worked with her on two projects, an authorized biography of L. RON HUBBARD and the Mission Corporate Category Sort Out (MCCS). Laurel and I were involved in MCCS when the project was initiated, before the Church sought any legal advice and before the September 1980 meetings occurred, (which are

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described in my earlier declaration transcribing portion of the taped meetings).

2. The MCCS Mission was initiated from orders we received from L. RON HUBBARD. HUBBARD ordered me and Laurel Sullivan, among others, to figure out a way in which his control of the Churches of Scientology could be hidden, yet he would still maintain de facto control. This was done to hide HUBBARD's control of the Church of Scientology and the numerous benefits he inured from it. If HUBBARD's control was known, he would become involved in the litigation confronting the Church. His inurement of Church benefits would also affect litigation with the Internal Revenue Service which was then being fought concerning the Church of Scientology's tax exempt status. The whole purpose of the MCCS Mission was to defraud the federal government, litigants against the Church, and the courts into believing HUBBARD had no involvement with the Churches of Scientology, and therefore was protected from litigation. The corporate restructuring of the Church was to be performed to meet this objective. All of the activities performed by anyone involved in the MCCS Mission, including the attorneys, were done to achieve this fraudulent end.

3. The two September 1980 meetings described in my prior declaration were part of a series of meetings, whose purpose was to obtain the fraudulent anal illegal objectives of the MCCS Mission described above.

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4. Barbara De Celle was also involved in the MCCS Mission. She borrowed the tape recorder and the tapes used to record the September 1980 meetings described in my prior declaration from me. Several Months later in the summer of 1981, she gave me these tapes of the September 1980 meetings and told me they belonged to the L. Ron Hubbard biography project. At that time, I was working exclusively as a research assistant to Omar Garrison, the author hired to write the biography of HUBBARD. De Celle and everyone else who was on staff knew that any materials that were given to me for the biography would be turned over to Garrison. Garrison had no connection with MCCS and was not even a Scientologist. After Barbara De Celle gave me the tapes, I turned them over to Garrison.

5. Barbara De Celle voluntarily gave me the tapes of the September 1980 meetings of her own volition. I never asked for them. Nor did I surreptitiously take them from her desk. She gave them to me one day as I passed by her desk.

6. I have described these tapes in other affidavits which I have signed. One such affidavit was executed in the summer of 1982 for use in the case of Burden v. Church of Scientology of California, Middle District of Florida, C.A. No. 80-501-Civ-T-K. To my knowledge, my description of those meetings, which is the same as the description contained in the

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declaration I filed in this case is still part of the public record of the Burden case, and has never been stricken.

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

Executed this 11th day of February, 1985 in Los Angeles, California.

[signed]
GERALD ARMSTRONG
Declarant

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