I Gerald Armstrong, depose and state:

1. I am a Canadian citizen and a resident of San Anselmo, California, USA.

2. I am a writer and artist and I am the assistant of attorney Ford Greene.

3. I am making this statement with the intention that it be introduced in the trial now set for February 21, 1994 in the High Court in London of cases 1984 S No. 1675 Scientology AOSH Eu & Af -v- Scott, et al and 1986 C No. Scientology RECI -v- Carter, et al.

4. It is my understanding that these cases involve the taking and distribution of certain Scientology writings often referred to as "upper level materials." I am a witness to the following facts which will be raised at trial.

5. 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 (SO or Sea Org), Scientology's quasiparamilitary core organization in Los Angeles. I was flown to Spain and joined the Sea Org's flag ship, " Apollo," in Morocco. L. Ron Hubbard, the Sea Org's " Commodore," 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

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countries the "Apollo" visited. These on-board positions included "Ship's Representative"/legal representative, " Port Captain" /public relations officer, and "Information Officer"/ intelligence officer.

6. 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 handling 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 Clearwater, Florida unit of the "Rehabilitation Project Force" (RPF), the SO prison system. 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 first in La Quinta, then at a newly purchased base in Gilman Hotsprings near Hemet, California. From the time 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, as the "Purchaser," "Renovations In-Charge" and " Deputy Commanding Officer HU."

7. 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

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Personal Researcher." I assembled in Los Angeles an archive of Hubbard's writings and other materials relating to his history to be used as, inter alia, 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 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 known 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.

8. Through my research and study of documentary evidence, mostof it from Mr. Hubbard's personal archive, I learned that he 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 I attempted to get the organization executives responsible for these publications to correct the

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disproved claims. As a result I was 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 disproved 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 WW 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.

9. Following my departure the organization published a " Declaration" dated February 18, 1982 labelling me a "Suppressive Person (SP)." The terms "SP" or "suppressive person" are painful hate words, which have the effect of instilling terror in the people so labelled. An SP is described in Scientology's literature as completely psychotic and destructive, one of the

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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 philosophy and practice of opportunistic hatred Hubbard called the "Fair Game Policy," which states specifically that enemies may be lied to, cheated, sued and destroyed without discipline of the Scientologist committing such acts. My SP Declare 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, and I had detected organization personnel spying on my wife and me. The organization also appropriated a set of photographs I had entrusted with an associate,.Virgil Wilhite, and when I demanded their return one of Hubbard's lieutenants told me to get a lawyer.

10. A few days later I met with 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 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 they would bring against me

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in the non-Scientology courts. I sent these to Mr. Flynn and to Contos and Bunch, a California law firm which by then had agreed to represent me in Scientology litigation. The organization filed suit against me in the Los Angeles Superior Court on August 2, 1982 and the Hubbard biography documents I had sent to my lawyers were ordered by the Court to be deposited with the clerk where they stayed until December, 1986.

11. In August and September 1982 the organization employed a number of private investigators to surveil 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 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 litigation in the Superior Court.

12. I filed a cross-complaint in 1982 against various Scientology corporations for fraud and the intentional infliction of emotional distress. The cross-complaint was bifurcated from the underlying document case and never tried because it settled in December 1986. The document case was tried without a jury by Judge Paul G. Breckenridge, Jr. who rendered a decision on June 20, 1984. Judge Breckenridge's decision is appended hereto as Exhibit [A]. The opinion of the California Court of Appeal, Second Appellate District, Division Three issued July 29, 1991 affirming

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the Breckenridge decision is appended hereto as Exhibit [B]. Between that time and the settlement the organization continued its "fair game" campaign against me which included at least these acts: a) attempted entrapment; b) illegal videotaping; c) filing false criminal charges against me with the Los Angeles District Attorney; d) filing false criminal charges against me with the Boston office of the FBI; e) filing false declarations to bring contempt of court proceedings against me on three occasions; f) obtaining from English private investigators, who had harassed me in London in 1984, perjured affidavits accusing me falsely of passing documents to a bearded stranger in the Olde Cock Tavern on Fleet Street; disseminating internationally Scientology publications falsely accusing me of crimes, including crimes against humanity; g) culling and disseminating information from my supposedly confidential auditing (psychotherapy) file.

13. Following the December 1986 settlement the organization continued its fair game campaign against me in violation of the spirit and letter of the settlement agreement. The organization's violations include at least: a) use of my name and a false and unfavorable description of my organizational experiences in 1987 in a "dead agent" pack relating to writer and anti-Scientology litigant Bent Corydon; b) filing several affidavits in the fall of 1987 in the case of Church of Scientology of California v Russell Miller and Penguin Books Limited, case no. 6140 in the High Court of Justice in London England, falsely accusing me of violations of court orders in the

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Armstrong case, and falsely labeling me "an admitted agent provocateur of the U.S. Federal Government;" c) delivering a copy of an edited version of the 1984 illegal videotape of me to the London Sunday Times; d) threatening me with lawsuits on six occasions if I did not abet the organization's obstruction of justice; e) threatening to release a description I'd written of a dream I'd had, and which the organization had stolen from a friend of mine, if I did not assist the organization in preventing Bent Corydon from gaining access to the Armstrong court file; f) using my name and a false rendition of the organization's 1984 videotape operation where organization intelligence operatives attempted to entrap me into the commission of a crime in the case of Church of Scientology International v. 17 Agents, case no. 91-4301 SVW filed August 12, 1991 in US District Court, Central District of California; g) using the same false rendition of the 1984 "Armstrong Operation, " perjurious declarations by organization lawyers and a general attack on my character and truthfulness in various pleadings filed in August and September, 1991 in the case of Aznaran v. Church of Scientoloqv of California, et al, No. CV 88-1786 JMI in US District Court, Central District of California; h) suing me in 1992 and twice more in 1993 for alleged violations of the 1986 settlement agreement based on the false statements of the organization's lawyers and its leaders; i) two times in 1993 attempting to have me jailed for contempt of court based on the false sworn statements of its lawyers; j) distributing copies

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internationally of the 1985 dream organization lawyers had threatened to release as stated in e) above (I wrote this recitation of a dream, which was sexual in content, in a graphic, vulgar style, and the way the organization has perverted its significance has made its distribution embarrassing and distressing to me. The dream was specifically sealed in the Los Angeles Superior Court arid the organization has violated that sealing order in order to use this document to attack me); k) using its head private investigator to spread the lie that I have AIDS.

14. I have testified approximately--55 days in trial. or depositions in more than 15 Scientology-related cases. I am an expert in the fraudulent nature of Scientology and its use of "fair game," and I have testified as an expert in these areas. I am also knowledgeable regarding the organization's efforts to hide its actual control and to shield those who control it from legal responsibility with "buffer" corporations, secret orders, secret command lines, organization-wide agreement to lie to protect those in actual control, and threat of extreme retribution toward anyone who violates that agreement to lie.

15. In his decision, Judge Breckenridge found:

"In addition to violating and.abusing its own members civil rights, the organization with its "Fair Game" doctrine has harassed and abused those persons not in the Church whom it perceives as enemies. The organization clearly is schizophrenic and paranoid, and

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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." (Exhibit A, p. 8, 1. 18 - p. 9, 1. 4).

I observed the organization's abuse of its members' civil rights throughout the years I was inside. This abuse included false imprisonment; use against people of their statements made in supposedly confidential auditing-sessions; use of auditing techniques in a coercive manner, e.g., security checks to find "traitors" or "security risks," or to "turn on rockslams" by which the person would be assigned to the RPF, which is itself an abuse of basic human rights, and is itself a setting in which auditing is coercive, since a person cannot get out of the RPF unless he or she submits to auditing; the practice of disconnection, which breaks apart and alienates families; tricking or forcing members to lie, including perjuring themselves in sworn testimony in legal proceedings; threat of "ethics," "Fair Game," RPF, disconnection and dirty tricks; and denying its members access to the truth about the nature of the organization while subjecting them to an unending barrage of distortions, half-truths and outright lies.

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16. In a case the organization filed against me in 1992 to enforce the December, 1986 settlement agreement, Los Angeles Superior Court Judge Ronald M. Sohigian stated on May 27, 1992:

"The information (Gerald Armstrong's experiences inside the Scientology organization) that's being suppressed in this case, however, is information about extremely blame-worthy behavior of [the Scientology organization] which nobody owns; it is information having to do with the behavior of a high degree of offensiveness and behavior which is meritorious in the extreme. It involves abusing people who are weak. It involves taking advantage of people who for one reason or another get themselves enmeshed in-this extremist view in a way that makes them unable to resist it apparently. It involves using techniques of coercion."

The pages from the transcript of the hearing before Judge Sohigian in which he made this statement are appended hereto as Exhibit [C].

17. I was myself enmeshed in Scientology's extremist view for many years and have known personally hundreds of other people just as enmeshed. I am also known by hundreds of people around the world as someone who brought to light the truth about L. Ron Hubbard's history, through his documents which were used in evidence at my 1984 trial and through my willingness to talk freely about what I had found in my assembly and study of his documents. Many people have thanked me personally for exposing

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the truth as I saw it about L. Ron Hubbard and his organization, and for thus freeing them from the lies which had kept them enmeshed in the organization's extremist view. The exposure of any of the organization's "secrets," including the " upper level materials" serves the same purpose; that is, it frees people from the organization's unhealthy and often dangerous domination. One of Hubbard's and his organization's techniques of domination was to claim possession of secret knowledge, which they also claim is vital to the sanity, health and future of everyone under their control, and for which the organization charges astronomical sums of money to view. Exposure of these "secret" materials reveals them for what they really are: more techniques and untruths to further enmesh the organization's victims. Exposure is in the public interest.

This statement is true to the best of my knowledge and belief.

Exhibit [A]
Breckenridge Decision

Exhibit [B]
283 Cal.Rptr. 917

Exhibit [C]
Hearing Transcript Excerpt 05-27-1992