Notice of Libel and Slander

David Miscavige
C/O Religious Technology Center
1710 Ivar Avenue, Suite 1100
Los Angeles, CA 90028

Religious Technology Center
1710 Ivar Avenue, Suite 1100
Los Angeles, CA 90028

Church of Scientology International
6331 Hollywood Boulevard
Los Angeles, CA 90028

Church of Scientology Toronto
77 Peter Street
Toronto, ON M5V 2G4

Patricia Felske
C/O Church of Scientology Toronto
77 Peter Street
Toronto, ON M5V 2G4

Earl Smith
C/O Church of Scientology Toronto
77 Peter Street
Toronto, ON M5V 2G4

Also by Email to RTC, CSI, CSTO
Dear All:


During the “Getting Clear” conference on Scientology fraud, abuses and criminality at the Toronto Airport Sheraton in June, I received from Dr. James. A. Beverley a copy of one of your black propaganda packs, or part of one of your black propaganda packs, which contains statements that are highly defamatory of me.

I am aware that there is no requirement that I give you any notice before filing a claim in court for defamation, and you are not entitled to the benefits of such a notice, since the defamatory statements were published and disseminated in a printed black PR document in a printed black PR pack. Nevertheless, in an abundance of caution, for the mitigation of damages, and to give you maximal opportunity to correct your defamatory statements and repair the damage you have caused, I am writing to put you on notice with respect to these defamatory statements. I am asking that you immediately correct your defamatory statements, which are enumerated below, and repair to my satisfaction the damage caused.

Dr. Beverley confirmed that Earl Smith and Patricia Felske as official, authorized representatives of Scientology entities and Scientologists gave your black PR pack to him by hand at a meeting in a Pickle Barrel on Leslie Street in Toronto, Canada on June 16, 2015. I first received from Dr. Beverley what he said is a photocopy of the complete Smith and Felske black PR pack on June 26. Dr. Beverley also stated that Smith and Felske also defamed me orally during their meeting. For your reference, I have posted a .pdf of your black PR pack, as I received it from Dr. Beverley, at:

Your numerous statements about me in your Smith and Felske black PR pack, which are false, misleading or defamatory include the following:

  1. Atack’s “book” relied exclusively on “stories” dredged up from a handful of fellow apostates, particularly Gerald Armstrong, a notorious liar who boasted about fabricating documents regarding Scientology
  2. False Allegations from Gerald ArmstrongThe primary source of the above false claims of Jon Atack, was Gerald Armstrong. Armstrong was Atack’s source for claims about L. Ron Hubbard’s childhood, his education, his military service and his career as an author.
  3. Truth:Gerald Armstrong has spent nearly three decades campaigning against L. Ron Hubbard and the Church of Scientology. A former clerk in L. Ron Hubbard’s archives, Armstrong abruptly left the Church in December 1981, stealing many of Mr. Hubbard’s private papers. The papers included the diaries of a young L. Ron Hubbard as a travelled in the orient as a teenager, personal letters and journals and other documents. Armstrong used these papers, coupled with his own lies about them and other false information as the source material for Atack’s book.
  4. One of Armstrong’s tricks is to claim he saw things in the archives that were never there, trying to force the Church to produce private papers of the Scientology Founder to defend against his claims.
  5. Armstrong made himself such an important pivotal source of information for Atack, his own credibility is at issue. In December 1986, several Scientology churches settled outstanding litigation with Gerald Armstrong arising from Armstrong’s December 1981 theft of thousands of personal documents belonging to L. Ron Hubbard, the Founder of the Scientology religion, and Armstrong’s use of those documents to generate false media articles and to foment groundless civil litigation in several venues.
  6. That settlement included the provisions that Armstrong would return all of the documents and cease his campaign of harassing Scientology churches and Scientologists. At one point in a police-sanctioned investigation, Armstrong was recorded seeking original Church documents he could use as templates for documents to be planted in Church files. He told an individual he thought was an accomplice, “I think that during part of this, we can simply create these, I can create documents with relative ease (laughter), you know, I did it for a living!”
  7. Armstrong remained quiet until 1990 when he gave away his assets and embarked on a new round of harassing actions that have continued to this day. These have included voluntarily aiding adverse litigants and potential litigants, providing interviews to media in the United States, Canada, Great Britain and Russia, addressing conventions and harassing individual Scientologists and Scientology churches.
  8. On April 9, 2004, the Marin County Superior Court again upheld the 1986 settlement agreement and found Armstrong liable for breaching it by publishing 131 documents on the Internet. The court awarded the Church $500,000 in damages.
  9. Having been a fugitive since 1997, Armstrong finally appeared for his contempt sentencing. The contempt orders were discharged with a sentence of five days in jail and a fine of $1,000. The Court of Appeal reversed this ruling holding that the contempt citations were improperly discharged. Thus, on October 9, 2007, the Court reinstated sentences of 28 days incarceration, and a fine of $1,000. The Court issued a bench warrant for Armstrong’s arrest the same day.
  10. In total, since 1992, Armstrong has been found by judges in two separate courts to have breached his settlement agreement 188 times and to have violated court orders enforcing the terms of the settlement 145 times. The Church has obtained a permanent injunction; two awards for damages, attorneys’ fees and costs totaling $1,150,000; and three contempt of court citations, for which Armstrong was fined $1,000 and ordered to spend a total of 28 days in jail.
  11. Armstrong once posted a message on the Internet concerning a letter he sent to Saddam Hussein during the Gulf War. In the letter, he offered himself to Hussein as a hostage in the Iraqi war. “If either side failed to perform any part of the agreement, the other side could execute me,” he concluded.
  12. His mental state is further illustrated by his rendition of a bizarre dream he had that involved a talking pig.
  13. To further demonstrate how out of touch he is with reality, Armstrong had himself photographed by a newspaper naked while holding a globe to promote his theories of destroying all money.
  14. Credibility finding against Armstrong and AtackIn October, 1997, the Italian Supreme Court the Court of Cassation) issued, a landmark decision recognizing the religious bona fides of Scientology and ending years of harassing police investigations. The Court thoroughly analyzed the criteria for defining a religion, stressed the government’s duty not to restrict religious freedom and concluded that Scientology has in common with other faiths the criteria necessary for it to be considered a religion (Page 32). As part of its analysis, the Supreme Court specifically dismissed inflammatory and scurrilous allegations by Armstrong and Atack on the grounds that they are not credible witnesses. The Court criticized the Court of Appeals for its failure to verify the information from these individuals, to ascertain the reasons for their estrangement from Scientology and to determine whether their statements were gathered in a judicial proceeding where their veracity could be examined and tested (pages 34 – 35).
    Document:12. Italian Supreme Court Decision of October 1997

These statements individually and together create a false, calumnious and devastating image of me. I am very aware of the savage and criminal intention toward your black propaganda targets, which, in addition to the intention to disparage me, underlies your black propaganda publications and campaigns. Consequently, your statements about me in your Smith and Felske black PR pack are also extremely threatening.

I am aware that the Smith and Felske black PR pack is only one of many such black PR packs or materials containing statements defaming me that you have caused to be created and disseminated on many occasions in many locations to many people and entities. I am also aware that the defamatory statements identified above do not stand alone but comprise only the most recent instance I am aware of in a very long criminal conspiracy by yourselves and others against my rights and person.

Exacerbating the defamatory quality of the Smith and Felske black propaganda, they both present themselves as responsible, upright, ethical citizens, who give public speeches on topics such as truth, honesty, religious tolerance and ethics. Scientology leaders and Scientology entities all also present yourselves as honest and ethical, and in fact claim ethics and ethics “technology” that are superior to all wog ethics and ethical systems.

The false statements about me in the Smith and Felske black PR pack you know and knew were false. Your defamatory statements are intentional, willful and malicious. They are also sadistic because you intend harm with your statements that you know are false. Your statements far exceed the limits of free speech.

I firmly believe that your documents in the Smith and Felske black PR pack that concern other individuals, specifically Dr. Alexander L. Dvorkin, Ursula Caberta, Tony Ortega, Pete Griffiths and Jon Atack, also contain false statements and are also defamatory, and evidence your clear intention to smear us all by association with each other.

It is my understanding that I have something of a duty to take reasonable steps to determine what defamatory statements have been made about me, in addition to what I already know about in the Smith and Felske black PR pack. Therefore I am asking each of you Scientologists or Scientology entities to please forward to me all of the materials, documents, audio or video recordings, or statements of any kind in your possession or control that mention me or relate to me in any way so that I can examine them for additional defamatory statements. The Smith and Felske black PR pack contains a reference, for example, to several such documents that were not included in what Dr. Beverley gave me on June 26.

Please let me know immediately of your intention regarding correcting the false and defamatory statements in the Smith and Felske black PR pack and regarding making up for the damage you have done.


Gerry Armstrong (Sig)

Gerry Armstrong