I, Gerald Armstrong, depose and state:

1. I am a citizen of Canada and reside in San Anselmo, California, USA.

2. I am by trade a writer, artist and philosopher. I am also a paralegal and I am working in that capacity in the law office of attorney Ford Greene in San Anselmo. I am presently involved in litigation concerning the Scientology organization, hereinafter referred to as "the organization," as a paralegal, witness and defendant.

3. I am writing this affidavit at the request of Reader's Digest to provide some of my knowledge regarding certain charges first made about the organization in the Time magazine article, "The Thriving Cult of Greed and Power," condensed in the Reader's Digest article, "Scientology: A Dangerous Cult Goes Mainstream."

4. I was a member of the organization from 1969 to 1981 and held several staff positions in various organization locations and units. During that period I gained an intimate knowledge of organization structure, policies and practices. In 1982, I was declared an organization enemy and have been involved in organization litigation and the target of organization attacks ever since.

5. From February 1971 until September 1975 I was, except for short periods when I was sent on organization missions ashore, stationed on board the ship "Apollo," then the " flagship" of the Sea Organization. The Sea Org is the organization's

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paramilitary arm, members of which sign a billion year contract. Throughout the time I was on board, L. Ron Hubbard, the organization's founder and the Sea Org's Commodore, ran all of Scientology internationally from the ship, through his aides, the management bureaux and his Commodore's Messengers.

6. From the beginning of 1972 until 1974, I held the position of Ship's Representative or legal officer. In 1974 I held the positions of Port Captain and public relations officer. From the fall of 1974 until I left the ship in 1975 I was posted as the ship's Intelligence Officer. During those years I dealt with the immigration, customs, police and port authorities in all the countries the ship visited, and was actively involved in and knowledgeable of the ship's relations and problems in those countries. During 1974, the ship was ejected from Portugal and denied entry into Spanish ports. In 1975, the ship was denied entry into Barbados and ordered to leave Trinidad. I also learned through the study of organization documents while assigned to legal or intelligence positions on board, and the study of Hubbard's personal records when I was assigned to do the research for his biography in 1980 through 1981, that Hubbard and the ship had fled from England, that Hubbard was prohibited from entering England, and that the ship had been ordered to leave Greece. The ship experienced problems of social or official rejection in virtually every port it entered. Based on my experiences and my knowledge of organization operations, I formed the opinion that the rejection in each instance stemmed from

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Hubbard's and the organization's dishonesty. On Hubbard's orders all of the over four hundred people on board were required to lie about who we were, what we were doing, who ran the organization and what our intentions were. Hubbard's and the organization's insulting deceitfulness precipitated the antagonistic reactions in all the ship's ports of call.

7. Hubbard and the topmost clique of his organization enforced his policies and orders inside the organization and acted toward critics or any designated enemies outside the organization with threats, intimidation and force that is similar to the way the mafia is reputed to control its members and deal with perceived threats to its operations and leaders. Internally, Hubbard used the organization's prison system, known as the Rehabilitation Project Force or RPF, and threats of punishment or actual punishment, which could range from performing menial tasks as "amends," to being locked up in the ship's anchor chain locker or thrown overboard. Individual organization members whom Hubbard considered crossed him in any way would be forcibly ordered to the RPF, a humiliating existence where even the few rights of non-RPF organization members were stripped from them. While inside the organization, I was locked up and guarded on Hubbard's orders and assigned to the RPF on one occasion for seventeen months for allegedly antagonizing Mary Sue Hubbard's secretary, and on another occasion for eight months because Hubbard considered that I was joking about his movie-making abilities. I personally know of hundreds of good people

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who were assigned to the degrading conditions of the RPF for the sole purpose of breaking their will in order to make them unthinkingly compliant with Hubbard's and his emissaries' desires.

8. Hubbard and the Sea Org seniors which ran the organization employed a broad array of techniques, some blatant and some insidious, but all reminiscent of totalitarian regimes or criminal groups, in order to maintain psychological and behavioral control over organization members. Members spied on each other and reported secretly any observed deviation from the enforced norm of unquestioning obedience. Members were routinely ordered to be security checked, or "sec checked," an invasive interrogation procedure employing an electropsychometer, or E-meter, as a lie detector. Members were also routinely ordered to write up their overts and withholds, (O/Ws), which are also called "crimes," and might include actual felonies for which the members could be prosecuted, thoughts critical of Hubbard or the organization, or even desires which deviated from organizationlly defined intentions. Members' lists of O/Ws and confessions extracted during sec checks were maintained in organization intelligence files and used as a threat to ensure obedience as well as to intimidate and suppress members should they ever leave the organization and speak out against its abusive practices. For public relations purposes, the organization insists that statements of persons undergoing counseling, or "auditing," are confidential between them and their "auditor," but these

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statements or confessions were routinely provided to organization intelligence and enforcement personnel, and would be used by the organization in any manner that suited its purposes. Organization members were also regularly and publicly labeled by higherups with names such as "traitor," "enemy" or " saboteur." Members were also required to publicly so label themselves and even accuse themselves of horrible imaginary "crimes," such as threatening the future of all mankind. Members were kept inside the organization by the threat that to leave, or even plan to leave, is a criminal act for which they would be declared an enemy and made subject of the "fair game law."

9. In the organization's early years Hubbard formulated a philosophy of opportunistic hatred, which he called "Fair Game, " in order to justify his bullying and terrorist tactics toward anyone or any group he didn't like. In his published fair game doctrine he stated that anyone declared an enemy "may be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist...may be tricked, sued, lied to, or destroyed." To carry out covert operations pursuant to his fair game policy, Hubbard established within the organization an international intelligence bureau which he patterned after Nazi Germany's intelligence apparatus. I am very familiar with the organization's intelligence system and operations because I worked within it and have been its target since leaving the organization. Hubbard and the organization also employ private investigators (PIs) to harass, intimidate and ruin, by whatever

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means are available, perceived critics. These PIs are often former police officers or off-duty police officers with ties into law enforcement agencies. Since I left the organization I have been tailed, spied on, threatened and assaulted by organization PIs. One PI attempted to involve my wife and me in a freeway accident, one threatened to put a bullet between my eyes and others have made false sworn statements about me. Organization operatives attempted to inveigle me into the commission of a crime, and videotaped me, claiming they were permitted to electronically spy on me by a fraudulent authorization from a corrupted Los Angeles Police Officer, who was suspended six months from the police force for giving organization agents such false authorization.

10. Pursuant to Hubbard's fair game doctrine the organization also employs countries' justice systems to harass, intimidate, silence and destroy its critics. Since I left the organization it has sued me twice, taken my deposition for purposes of harassment for more than twenty-five days, brought false contempt of court charges against me on three occasions, and attempted to have false criminal charges brought against me by the Los Angeles Police Department, the Los Angeles District Attorney and the US Federal Bureau of Investigation. The organization also employs corrupt lawyers to terrorize its critics with false charges, frivolous lawsuits, abuse of the legal process, manipulation of the courts and senseless legal actions intended to overwhelm and to bring about the perceived

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critics' financial decimation. Organization lawyers have filed a multitude of perjurious statements about me in courts internationally, and have aided the organization in its attacks on my person and reputation, both directly and by acting as cutouts between the organization and its intelligence and PI operatives. Organization lawyers have participated in the culling of my "confidential" preclear folders in order to use the "confidential" materials in court against me. Organization lawyers also spearhead the organization's attacks on its opponents' lawyers. My own lawyer in the organization litigation until December 1986, Michael J. Flynn of Boston, Massachusetts, was sued by organization lawyers at least fourteen times and hounded with concocted bar complaints. Organization lawyers participated in an international effort to frame him with crimes and to destroy his reputation and career. In December 1986 as a direct response to organization threats to his life, family and business, Mr. Flynn capitulated, withdrawing completely from representation of anyone involved in litigation with the organization.

11. The organization's public defense line to the accusations of criminal, bullying and antisocial behavior is that a new group of leaders had taken over in 1982 and thrown out the old group of "criminals," who had been responsible for the organization's legal problems. Indeed the old group, including Hubbard's wife, Mary Sue Hubbard, had been involved for many years in criminal, and antisocial acts and conspiracies, and Mrs.

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Hubbard and ten of her coconspirators were convicted of federal crimes and sentenced to prison. L. Ron Hubbard, however, who had in truth established Mary Sue's criminal network and was behind all the felonies for which the "criminals" had been convicted, continued to run the organization. He merely replaced Mary Sue's group with another, even more ruthless, coterie of Sea Org members. He changed the name of the organization arm Mary Sue had headed, the "Guardian's Office," which included the intelligence bureau, to the "Office of Special Affairs." The functions remained the same, and the new agency continued Hubbard's practices of attacking and smearing critics, terrorizing members and non-members, abusing the legal process, destroying civil rights, and perpetrating assaults, theft, blackmail, and whatever else served their purposes, in the name of "fair game."

12. In December 1986, I entered into a settlement agreement with the organization which was to compensate me monetarily for my claims against the organization resulting from the many years of abuse and the attacks since I left in 1981, and to end the attacks and continual threats. The organization, after it removed my lawyers from defending me, however, did not honor the agreement, but renewed its policy and practice of opportunistic hatred toward me. Since the settlement the organization has filed numerous false statements about me in courts internationally and accused me of crimes which the organization itself manufactured. It has libeled me to the press and public,

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spied on, videotaped, and terrorized me, sued me for acts it forced on me and is actively trying to destroy my job and livelihood and have me removed from my residence.

13. Attached hereto is a copy of my valid Canadian passport.

14. In delivering this testimony I know that it is destined to be produced in Court. I also know that false statements are criminally punished.

[signed]
Gerald Armstrong