Declaration of Gerald Armstrong

[CT 6251]

I, Gerald Armstrong, declare:

1. I have been informed by my attorney, Julia Dragojevic, that attorneys for plaintiff Scientology organization have advised her that they intend to tell the Court that the organization has now fully complied with the Court’s orders of July 2, September 9 and December 9, 1985 regarding production of documents. The purpose of this declaration is to show that the Court’s orders have not been complied with.

2. I have reviewed the documents received from plaintiff organization as my “B-1” file. This is offered by the organization as full compliance with original requests for production:

2. All originals and all copies of Guardians Office files pertaining to Gerald Armstrong.

3. All originals and all copies of correspondence of the Guardian’s Office pertaining to Gerald Armstrong.

Attached hereto as Exhibit [A] is a 14 page “time track” or chronology produced as part of the B-1 file. I have circled in red the date of 87 time track entries for which the documents from which they were extracted have been deleted from this “B- 1 file.”

3. “B-1” was a designation, known from a certain level upwards in the organization, for the Guardians Office intelligence bureau. B-1 gathered intelligence internally and externally and overtly and covertly, and it ran agents and

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[CT 6252]

carried out operations against enemies to frame them, compromise them, orotherwise nullify them as a threat. The GO also ran public relations, finance, legal, and they had, except for a couple o £ L. Ron Hubbard’s personal public relations officers, total control of any organization interfacing with government agencies, the media, law enforcement, private investigators, and enemies. The only thing the GO did not run was the auditing-training income-making apparatus of the organization. And that part of the organization would have no files on me. Within the GO each bureau had its own files. These files often related to enemies. “Freedom,” the organization’s tabloid black PR tool, was part of the GO. And the GO was itself a part and function of the Church of Scientology of California corporately and it was operated by Hubbard through his wife, the Controller. There has been a continuity in GO activities, and in many cases personnel, right to present time. The organization still puts out”Freedom,” it still does PR and black PR, it hires private investigators, lawyers, graphologists, etc., it has a finance bureau , and it has intelligence data gathering and covert operations; and it has files on me in each of these areas. Different organization units performing these functions from 1982 onward include Special Project, ASI, Religious Technology Center (RTC), Office of Special Affairs (OSA) (which is divided into OSA Pac(ific), OSA US, OSA Int(ernational), etc.), Mission All-Clear (MAC) (also with local, continental and international units), Commodore’s Messenger Organization (CMO) units, Watch-Dog Committee (WDC), and possibly others unknown. The corporation name personnel in these units supposedly worked for was

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[CT 6253]

irrelevant since Hubbard, the GO, and the messengers who took over the GO functions in 1981 by-passed all corporate lines. The last time track entry in the “B-1” file (see Exhibit [A]) is June 15, 1982. The organization had already begun its PI surveillance of Jocelyn and me, yet there is no time track reference to the PIs or their product. That the organization’s intelligence bureau was not running the PIs and not getting their product is a laughable impossibility. The real GO files on me, as for major enemies, would have been started in 1982. Before then there would have been an accumulation of some materials in my “B-1” file, notably everything from the three weeks I was locked up on Hubbard’s order in B-1 at GO US in 1976, but even this plaintiff organization has failed to produce. In the spring and summer of 1982 the organization escalated the attack against me— the PI’s, the assaults, the attempted criminal charges with the LAPD, many meetings with organization personnel, the London operation, the “Armstrong Operation” (or Sherman-Ingrain Operation), more attempted criminal charges with the LA DA and the FBI, media campaigns, “Freedom” campaigns. Yet the documents the organization offers end, but for a few exceptions, in the spring of 1982. Each of the operations or attacks is GO province and function. Organization attorneys are trying to make believe that if the name changed the function disappeared. An analogy would be the War Department under FDR becoming the Department of Defense. The functions remained the same and there was, as in GO activities, continuity until present time. The B-1 file produced is a joke. The organization is asking me to believe that after it raised me in importance to

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[CT 6254]

its number one or two enemy, all reports, correspondence, orders, evaluations, programs and operations concerning me ceased. The material received as “B-1” is a small fraction of the documentation in the organization’s actual intelligence files on me. Then there are the PR and legal files.

4. I refer the court to my declaration of April 9, 1986 in which I listed various incidents, operations or publications which were clearly organization creations and concerning which the organization had produced no documents. The facts of that declaration, except for the subsequent receipt of the partial “B-1” file, are essentially the same as they were then and I incorporate that declaration by reference herein. At page 14, no. 21 I described the documents still not produced concerning the “Armstrong Operation,” an organization intelligence operation which has been running from 1982 up to the present. The organization is still using the fruits of that operation, in fact, to make millions from its adherents (see p. 22, no. 6 of the April 1986 declaration). To prevent the organization from being able to completely sidestep the Court’s various orders regarding production of documents with the sham that the unproduced documents described in my declaration post-dated the renaming of the Guardians Office, Ms. Dragojevic served the organization’s attorneys with the request for production attached hereto as Exhibit [B]. This request lists the documents specified in my declaration as not produced in non-compliance with the Court’s orders. Request no. 21 asks for the documents relating to the “Armstrong Operation.” The organization’s response, signed by attorney John Peterson, is

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[CT 6255]

attached hereto as Exhibit [C]. Mr. Peterson stated in response to request no. 21:

“Armstrong Operation” is a characterization invented by Cross-complainant as no such “operation” has ever existed. Cross-defendant has no such documents in its possession, custody or control.

This is such a big lie it boggles the mind. “Armstrong Operation” is the organization’s term: however the operation’s name is irrelevant. If the organization labelled the operation “Armstrong Program,” “Destroy GA Plan” or ” Freakout II,” it does not matter. Mr. Peterson knows what is being referred to because he was and is an active participant in the operation. He filed sworn declarations in this case and in many more across the country, and with several government agencies. He used his perverse rendition of the operation, in fact in the “Further Opposition to Motion to Compel Production of Documents” filed with this Court May 8, 1985. If Mr. Peterson is believed, that there are no documents concerning an operation over almost 6 years involving dozens of people, incredible expenditures of money for extra-legal actions, a bevy of PIs, three countries, illegal videotapes, bugs, a paid-off dirty cop, millions of “Freedom ” tabloids devoted to the operation distributed internationally, manufactured evidence foisted on the LAPD, LA DA, Courts and the FBI, and a get-rich-quick scheme involving millions of dollars internationally, he sends a message back to his client organization that lies still work and it is still good strategy to thwart and abuse legal procedures.

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[CT 6256]

5. Attached hereto as Exhibit [D] is a series of daily reports concerning me from intelligence personnel in the Greater Los Angeles GO to posts in GO US covering the period from February 22 to March 18, 1982. This was before the first SP Declare was issued on me. As can be seen, intelligence daily reports were created for actions as simple as the stakeout of Omar Garrison’s residence even when nothing was observed. To say that the “Armstrong Operation” was created with no documentation, no orders and no funding, and that no reports were generated over four-plus years is beyond absurd. It should be noted that each of the individuals holding posts which received the reports or copies, also therefore possessed Armstrong documents and files.

6. Attached hereto as Exhibits [E], [F], [G] and [H] are documents entitled respectively “Juggernaut” Eval, Operation Freakout, Goodrich Suit Evaluation, and Christo Final Handling Eval. The Juggernaut document is a broad evaluation and program to attack Michael Flynn. The number of people involved is shown by the post distribution list on the first page. Freakout was an operation to frame a Scientology Critic, Paulette Cooper (PC) with a fake crime much as the organization has attempted with me on several occasions. The Goodrich document was written by Hubbard and is a model for attacking individuals with claims against the organization (see “Goodrich Eval” under the Policy section of the Juggernaut Eval). The same perfidious strategy used by the organization and its attorneys to invade my privacy cull and miscull my PC folders, and put the culled and misculled product, further distorted by their sinister minds, before the

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[CT 6257]

Court, is devised and ordered by Hubbard at page 14 of this document. The Christo Final Handling Eval, which is clarified by my affidavit of March 8, 1985, also attached as part of Exhibit [H], concerns in part bringing criminal charges against Julie Christofferson, her associates and family, on Hubbard’s orders. The organization similarly attempted bringing false criminal charges against me. Julie Christofferson was in Scientology for a few months in a fringe franchise when she was 17 years old. Yet the organization in compliance with Hubbard’s orders created this sophisticated program to destroy her, including use of her auditing session statements against her (see p. 2, operating target 4 under Libby/Eureka, Montana). It is unimaginable that the organization has done all it has to me, operation after operation, yet has no evaluations, programs or operations files concerning me. The only other possibility is that the organization and its attorneys have, in anticipation or violation of the Court’s discovery orders, destroyed the evidence of their operations against me.

7. Mr. Peterson’s response regarding a manuscript, artwork and other materials stolen from the trunk of my car on November 8, 1984 (see request no. 15 of Exhibits B and C) is:

Cross-defendant has no knowledge of any burglary of Cross-complainant’s trunk. Hence, cross-defendant has no such documents in its possession custody or control.

Attached hereto as Exhibit [I] are a letter dated November 9, 1984 from Ms. Dragojevic to Mr. Peterson and his reply dated November 30, 1984. Ms. Dragojevic advises Mr. Peterson of the theft and

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[CT 6258]

makes a demand for return of the materials stolen. He answers with accusations and threats. His claim now that his client has no knowledge of the burglary is just not true.

8. Another example of documents clearly withheld by plaintiff organization is in regards to the program to get the LA DA to bring criminal charges against me — ultimately to have me jailed. This is all part of the “Armstrong Operation.” At p. 23, no. 11 of the April 1986 declaration I showed, from the mouth of CSC, CSI, RTC and Hubbard attorney Earle C. Cooley, the existence of such documentation. The organization has produced none of these documents. A letter from the Office of the LA DA dated April 25, 1986, attached hereto as Exhibit [J], however, reveals that Mr. Peterson and organization personnel provided a mass of documentation, even more than I knew before then existed, to the DA. Mr. Peterson knows that I know because he got the DA’s letter. To consider that all this was done from no written orders, programs, evaluations or missions is madness. It should be noted that the recipients of the DA letter were all GO staff. Lyman Spurlock’s testimony at trial in 1984 that he (as ASI staff) and others got rid of the 1100 GO staff criminals is untrue. Ken Hoden was GO staff: in fact he was involved in the program on Hubbard’s orders to bring criminal charges against Julie Christofferson. Heber Jentzsch was a GO PR staffer for many years who was used for the organization’s frontal PR attacks on enemies. He continues to perform the same organization function. David Butterworth is a longtime GO staff member. When I knew him in the organization he was an aide to Mary Sue Hubbard in the Controller’s Office. John Peterson has been connected to

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[CT 6259]

the GO from the 1970’s.

9. The organization has likewise still not produced the documents specified in connection with the other operations listed in my April 1986 declaration. I will not restate all these operations or the relevant documents, however, each operation is GO territory and each document relating to each operation fits squarely under the Court’s various discovery orders. I cannot consider that the orders have been complied with until the documents relating to all operations are received. There are literally thousands of documents being withheld by the organization and its attorneys.

10. What the organization also is doing to avoid exposure and compliance with discovery orders is to strip the plaintiff “corporation” of its personnel, functions, buildings, assets and files. When I left the organization, the Church of Scientology of California (CSC), under Hubbard, was the entire GO, Sea Organization, and all Scientology above small outer organizations and franchises, which were even then under CSC/Hubbard control. Attached hereto as Exhibit [K] are pages from the deposition of Cynthia Morrow, “managing agent” of CSC, taken October 29 and 30, 1985 in the case of Church of Scientology of California v. Jordan, LA Superior Court No. C538 049. Ms. Morrow testifies that by 1985 CSC had been stripped of all money-making organizations (service orgs) and was merely an “Office of Special Affairs.” In the Christofferson case in Portland, Oregon, former Executive Director International, William Franks testified that in December 1981 CSC had a net worth of $340 million and $150 million in one Sea Org Reserves

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[CT 6260]

account alone. His testimony is attached hereto as Exhibit [L]. In the case of Wollersheim v. CSC, just tried in LA Superior Court, the organization submitted a financial statement, attached hereto as Exhibit [M], claiming a net worth for CSC of $18,667,947.00. On information and belief, in September CSC claimed that it had decreased its net worth another $6 million plus since the May financial statement was prepared, leaving a net worth of around $12 million. The organization’s various conveyances and corporate machinations, however, should not shield the organization from liability for its tortious and criminal acts, and should not provide an escape from non-compliance with discovery orders. The Court has already ruled on the alter ego issue in this case, and this reasoning is applicable to this discovery matter. The people who run CSC run all of Scientology, and they can produce any document having anything to do with me now in the possession of any Scientology unit, organization, corporation or individual.

11. Attached hereto as Exhibit [N] is an organization policy written by Hubbard entitled “Order Board and Time Machine.” In it Hubbard states as “a major policy:” “if it is not written, it is not true.” He goes on to set as policy: “Even when one gives a verbal order it is also written down.” There are literally dozens of organization policies insisting emphatically on the same thing: written orders, written compliances, written programs, written projects, written evaluations. Written orders, programs and missions are “word-cleared,”drilled,” and “done in clay” so they are fully understood. It is impossible with verbal orders or

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[CT 6261]

reports. Even if the organization is hiding its orders, reports and files on me electronically in its computer system, and even if under my initials or a code designation, they exist. “If it isn’t written it isn’t true,” and the insistence on everything being in writing is hard policy in all Scientology organizations. Virtually nothing except for body functions, at the Sea Org/GO/OSA/CSC level is done without written orders and a written record.

12. The organization’s strategy, beyond its direct attacks aimed at my personal destruction, is to lie and stonewall to hopefully delay the January 1987 trial, or make it, with obstructions of all kinds, unbelievably difficult to try the case.

The organization and its attorneys, who accuse me of conspiracy, are the conspirators in this paranoid and dangerous plan to thwart legal redress of their victims. The Court can move along the case and the discovery matters, and the organization’s assault on sanity and justice can be checked by enforcing full compliance with its various orders, and the intent of the law.

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

Executed this llth day of October, 1986 at Boston, Massachusetts.

[signed]
Gerald Armstrong

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Exhibit [A]
B-1 “Time Track” Chronology

Exhibit [B]
Request for Production of Documents 08- 04-1986

Exhibit [C]
Response to Request for Production of Documents 09-02-1986

Exhibit [D]
B-1 Daily Reports [Clerk’s Transcript Pages 6262 – 6275]

Exhibit [E]
Juggernaut Eval [.pdf]

Exhibit [F]
Operation Freakout

Exhibit [G]
Goodrich Suit Evaluation

Exhibit [H]
Christo Final Handling Eval