UNITED STATES DISTRICT COURT

	FOR THE NORTHERN DISTRICT OF CALIFORNIA

Religious Technology Center,		)  No. C-96-20207 RMW

		 					)

		Plaintiff,			)  

							)  

	v.			 			)  

							) Grady Ward (www.gradyward.com),					)  

							)  

		Defendant 			)    

							)

___________________________________)  

							)

	

Religious Technology Center,		)  No. C-96-20271 RMW

							)

		Plaintiff,			)

							)

	v.						)

							)

H. Keith Henson ,				)  

							)

		Defendant				)

                                   ) 

							)

Religious Technology Center,		)  No. C-95-20091 RMW

et al.,						)

							)

		Plaintiffs,			)

							)

	v.						)

							)

Dennis Erlich, et al.,			)  

							)

		Defendants			)

                                   ) 

		DECLARATION OF GERALD ARMSTRONG

	I, Gerald Armstrong, declare:

	1.	I have personal knowledge of the facts set forth in 

this declaration and could competently testify thereto if called 

as a witness.

	2. 	I am a writer, artist and philosopher. Theologically 

speaking I am a prophet. Speaking religiously, I am a Christian.

	3. 	I am an expert and have testified as an expert in the 

areas of the Scientology organization's structure, nature, 

philosophy, policies, practices, history, specifically regarding 

its notorious fair game doctrine, its fraudulent representations, 

its legal abuses and tactics, and its "theology."  I have 

testified, either in deposition or trial, over 60 days in 

approximately 20 Scientology related cases.  I have written and 

executed dozens of declarations, which I will supply the Court if 

requested, concerning my Scientology knowledge and experiences.  

I have stated most of the facts contained in this declaration in 

these earlier sworn statements.

	4. 	I have been sued by the Scientology organization five 

times since 1982 in its continuing effort to prevent me from 

speaking the truth and to destroy me financially.  I have been 

throughout this time a world-wide target of Scientology's 

character assassination campaign or "black propaganda," which it 

also calls "dead agenting."  To "dead agent" someone, according 

to Scientology founder L. Ron Hubbard, is to destroy a target's 

credibility so that someone else "kills" him.  I will list some 

of these acts below.  Scientology is controlled and directed by 

David Miscavige.

	5. 	Within the past three weeks I have obtained an internet 

account and have started reading the newsgroup alt.religion. 

scientology. Grady Ward (www.gradyward.com), defendant herein, posted a request for 

declarations concerning knowledge of fair game operations, and 

specifically ops involving organization private investigator 

Eugene M. Ingram.  Mr. Ward stated that the declarations are 

needed fairly urgently.  I have such knowledge, some of which I 

will provide below.  I am aware of the related cases before this 

Court, RTC v. Erlich, and RTC v. Henson, and will also provide 

this declaration to those parties.

	6. 	I am submitting this declaration directly to the Court 

because of an order filed October 17, 1995, a true and correct 

copy of which is attached herewith as Exhibit A, in the case of 

Scientology v. Gerald Armstrong, Marin Superior Court Case No. 

157680 ("Armstrong IV").  By that order, which became part of a 

"judgment" filed May 2, 1996, a true and correct copy of which is 

attached herewith as Exhibit B, I am prohibited from:

		"2.	Voluntarily assisting any person (not a government 

organ or entity) defending a claim, intending to defend a 

claim, intending to defend an arbitration, or intending to 

defend any claim being pressed, made, arbitrated or 

litigated by any of the Beneficiaries, regarding such claim 

or regarding defending, arbitrating, or litigating against 

it;

		3.	Voluntarily assisting any person (not a government 

organ or entity) arbitrating, or litigating adversely to any 

of the Beneficiaries;" (Ex. A, 8:1-7)

	7. 	The "Beneficiaries" are:

	-	The Church of Scientology International, its officers, 

directors, agents, representatives, employees, volunteers, 

successors, assigns and legal counsel;

	-	The Church of Scientology of California, its officers, 

directors, agents, representatives, employees, volunteers, 

successors, assigns and legal counsel;

	-	Religious Technology Center, its officers, directors, 

agents, representatives, employees, volunteers, successors, 

assigns and legal counsel;

	-	The Church of Spiritual Technology, its officers, 

directors, agents, representatives, employees, volunteers, 

successors, assigns and legal counsel;

	-	All Scientology and Scientology affiliated Churches, 

organizations and entities, and their officers, directors, 

agents, representatives, employees, volunteers, successors, 

assigns and legal counsel;

	-	Author Services, Inc., its officers, directors, agents, 

representatives, employees, volunteers, successors, assigns 

and legal counsel;

	-	The Estate of L. Ron Hubbard, its executor, 

beneficiaries, heirs, representatives, and legal counsel; 

and/or

	-	Mary Sue Hubbard;" (Ex. A, 7:8-28).

	8. 	By this order I am prohibited from providing this 

declaration to Mr. Ward, Mr. Erlich or Mr. Henson for their 

defense, since the plaintiff RTC is one of the "beneficiaries."  

Eugene Ingram, being Scientology's agent, is a protected 

"beneficiary" as well, as are all of its corporations' attorneys, 

including its attorneys herein.

	9. 	I am also prohibited by this order from:

		"5.	Discussing with anyone, not a member of [my] 

immediate family or [my] attorney, Scientology, the Church, 

and/or any of the Beneficiaries;" (Ex. A, 8:14-16)

Thus, I may not even, and remain in compliance with this order, 

tell Mr. Ward, Mr. Erlich, Mr. Henson, or anyone else being 

persecuted by the Scientology organization with its well known 

and well greased fair game machinery and operatives, one word of 

my knowledge concerning these persecutors, or that I am myself so 

persecuted.

	10. 	This order does not, however, prohibit me from 

voluntarily assisting a person judging litigations involving the 

order's "beneficiaries."  I believe that the United States 

District Court is a "governmental organ or entity" excluded from 

the prohibitions of the order.  (See, Ex. A, 8:1,2; 6,7) I am 

therefor providing the original of this declaration to the Court. 

 I also believe that it would be improper to send this 

declaration to the Court in secret, thus I am sending copies to 

the parties or their counsel.

	11. 	I believe the order and judgment are illegal on their 

faces, and obtained by Scientology through illegal tactics.  The 

"contract" which the "order" enforces was obtained by Scientology 

through threat, fraud, related criminal activities, and the 

vitiation of my lawyers.  I have appealed the judgment, and 

believe that I will prevail and be free from Scientology's very 

damaging, illegal and evil efforts to keep me suppressed and 

defenseless.  In the meantime, I am by this declaration making 

known some of Scientology's abuses, one of which is this order 

itself, and I am working for their cessation, for safety, peace 

and sanity on whatever channels remain to me.  I know that 

certain of Scientology's leaders and agents are vindictive, 

desperate and dangerous, and have targeted me as a major "enemy." 

 I believe I am in considerable physical danger at this time.  

What Scientology's leaders have done and ordered done to suppress 

and destroy me in the past 15 years is unbelievable, and these 

people evidence a continuing determination to keep that history 

of suppression and destruction from ever being believed or even 

known.

	12. 	Attached hereto as Exhibit C is a true and correct copy 

of a document entitled  "Mutual Release of All Claims and 

Settlement Agreement," (hereinafter, ""settlement agreement"") 

which was part of the December, 1986 "settlement" of my cross-

complaint in the first case in which Scientology sued me in 1982, 

Scientology v. Armstrong, Los Angeles Superior Court Case No. 

420153 ("Armstrong I").  Scientology's judicial enforcement of 

the "settlement agreement" resulted in the order and judgment 

appended hereto as Exhibits A and B.  I will describe in paras. 

22 through 32 below how Scientology obtained my signature on this 

document.

	13. 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 ("Sea Org" or "SO") in 

Los Angeles.  I was flown to Spain and joined the Sea Org's flag 

ship, "Apollo," in Morocco.  L. Ron Hubbard, the SO's 

"Commodore," and all of Scientology's supreme leader, 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 

countries the "Apollo" visited, and included "Ship's 

Representative" (legal officer), "Port Captain" (public relations 

officer), and "Intelligence Officer."

	14.  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, a relay terminal for 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 Rehabilitation Project Force ("RPF"), the SO prison 

system, in Clearwater, Florida.  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, initially in La 

Quinta, then at a newly purchased base at Gilman Hotsprings near 

Hemet, California.  When 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. 

 My posts included "Purchaser," "LRH Renovations In-Charge" and 

"Deputy Commanding Officer HU."

	15.  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 

Personal Researcher."  I assembled in Los Angeles an archive of 

Hubbard's writings and other materials relating to his history to 

be used as 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 a non-

scientologist writer 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 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.

	16.  Through my research and study of documentary evidence I 

learned that Mr. Hubbard 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 attempted to get the 

organization executives responsible for these publications to 

correct the false claims.  As a result I was deemed a threat, and 

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 debunked 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 World War 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.

	17.  Following my departure the organization published a 

"Declaration" dated February 18, 1982 labelling me a "Suppressive 

Person ("SP")."  An SP is considered in Scientology completely 

psychotic and destructive, one of the 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 

"Fair Game Policy," which states specifically that they may be 

lied to, cheated, sued and destroyed without discipline of the 

Scientologist committing such acts.  The "SP Declare" on me 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.  In April, 1982 the organization also illegally 

appropriated a set of photographs I had entrusted with an 

associate, Virgil Wilhite, and when I demanded their return told 

me to "get a lawyer."

	18. A few days later I met with Boston, Massachusetts 

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 late 

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 its leaders would bring against me in the non-

scientology courts.  I sent these to Mr. Flynn, who was at that 

time, and for the next four and a half years, the most effective, 

prominent and attacked attorney combating Scientology, and to 

Contos and Bunch, a California law firm, which by then had agreed 

to be local counsel for me against the organization.  Mr. Flynn  

 represented approximately twenty individuals with damage claims, 

and was in communication with hundreds of people involved in 

opposition to or knowledgeable about Scientology.  The 

organization filed the Armstrong I suit against me on August 2, 

1982, and the Hubbard biography documents that I had sent to my 

lawyers were ordered by the Court to be deposited with the Clerk 

where they stayed until trial in the spring of 1984.

	19. In August and September 1982 the organization employed a 

number of private investigators to spy on 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 in 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 civil litigation in LA Superior Court.

	20. I filed a cross-complaint for fraud and fair game in 

1982 against various Scientology corporations which was severed 

from the underlying document case and was never tried because it 

"settled" in December 1986.  The underlying document case was 

tried without a jury by Judge Paul G. Breckenridge, Jr., who 

rendered a decision on June 20, 1984, a true and correct copy of 

which is attached hereto as Exhibit D.  This document, known 

around the world as the "Breckenridge decision," rebukes 

Scientology's fair game doctrine and other abuses.  It was 

affirmed on appeal, Scientology v. Armstrong (1991), 232 

Cal.App.3rd 1060, 283 Cal.Rptr. 917.  Judge Breckenridge states:

	"In addition to violating and abusing its own members 

civil rights, the organization over the years with its 

"Fair Game" doctrine has harassed and abused those 

persons not in the [organization] whom it perceives as 

enemies.  The organization clearly is schizophrenic and 

paranoid, and 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." (Ex.D, 

8:18-9:4).

	21. 	Between the 1984 Breckenridge decision and December, 

1986 settlement, the organization's campaign against me included 

at least these acts:  attempted entrapment; illegal videotaping; 

breaking into my car and theft of personal writings and art; 

filing false criminal charges against me with the Los Angeles 

District Attorney; filing false criminal charges against me with 

the Boston office of the FBI; filing false declarations to bring 

contempt of court proceedings against me on three occasions; 

obtaining perjured affidavits from English private investigators, 

who had harassed me in London in 1984, which falsely accused me 

of distributing "sealed" documents; international dissemination 

of Scientology publications falsely accusing me of crimes, 

including crimes against humanity; culling and disseminating 

information from my supposedly confidential "auditing" 

(psychotherapy) file.  I know that the attempted entrapment, 

illegal videotaping, and filing false charges with the LA DA all 

involved Eugene Ingram, who had been thrown out of the Los 

Angeles Police Department for allegedly pandering and taking 

payoffs from a drug dealer.  In the fall of 1984 Mr. Ingram 

called me and threatened to "put a bullet between [my] eyes."

	22. 	The circumstances leading up to and at the time of my 

signing of the December, 1986 "settlement agreement" make 

understandable why I would sign such a bizarre document.  I had 

prevailed overwhelmingly in the defense side of Armstrong I.  My 

cross-complaint against Scientology was set to go to trial in 

early 1987.  Lawrence Wollersheim had in July, 1986, obtained a 

twenty-five million dollar jury verdict against Scientology, also 

in LA Superior Court.  By December, 1986 I had weathered five 

years of fair game.  Michael Flynn, my attorney and employer, who 

had represented me throughout Armstrong I, had been Scientology's 

fair game target for seven years.  The organization had sued him 

and/or his office more than a dozen times in various 

jurisdictions.  The organization had "black PRed" him around the 

world; infiltrated his office; stolen documents; contacted and 

paid known criminals for statements falsely accusing him of 

crimes (for a glimpse, see, e.g., U.S. v. Kattar, 840 F.2d. 118); 

paid some of his former clients to execute false sworn statements 

attacking him; framed him with an attempt to cash a forged check 

on one of L. Ron Hubbard's bank accounts; and attempted to bring 

false criminal charges against him.  He expressed in many ways an 

abiding concern that his family was at physical risk.  Eugene 

Ingram was involved in and largely responsible, as Scientology's 

paid agent, for framing Mr. Flynn and attempting to have him 

charged criminally.  Mr. Flynn several times made the statement 

to me, and publicly to hundreds of others, that he believed 

Scientology had attempted to have him killed by tampering with 

his private plane.  He filed his own lawsuits against Scientology 

and Mr. Hubbard in response to the fair game attacks.  

	23. 	During the years the organization carried out its war 

on Mr. Flynn, organization lawyers had communicated and met with 

him on a number of occasions regarding settling his and his 

clients' cases.  I knew that such meetings occurred because I was 

one of those clients from early 1982 and I had worked for Mr. 

Flynn from September, 1985 through 1986 in his office in Boston. 

 Around the beginning of December, 1986 Mr. Flynn called from Los 

Angeles, where he was meeting with Scientology's lawyers to say 

that a "global settlement" had been reached.  He already had my 

agreement on a monetary figure for which I would settle my 

lawsuit.  He was to be paid a lump sum which he was to divide 

between his clients and himself. 

	24. 	I have in the past waived my attorney-client privilege 

as to my conversations with Mr. Flynn at the time of and 

concerning the "global settlement," and I again waive that 

privilege as to those conversations.  I have stated these facts 

in several declarations since 1990.  On December 5, 1986 I was 

flown to Los Angeles, as were several other of Mr. Flynn's 

clients from various places, to participate in this settlement.  

Shortly after my arrival in LA I was shown a copy of the 

"settlement agreement" (identical in all important respects to 

Exhibit C hereto) and some other documents, which Mr. Flynn 

indicated I was to sign.

	25. 	Upon reading the settlement agreement draft I was 

shocked and heartsick.  I told Mr. Flynn that the condition of 

"strict confidentiality and silence with respect to [my] 

experiences with the [organization]" (Ex. C, 7D), since it 

involved over seventeen years of my life, was impossible.  I told 

him that the "liquidated damages" clause (Ex. C, 7D) was 

outrageous; that pursuant to the settlement agreement I would 

have to pay $50,000.00 if I told a doctor or psychologist about 

my experiences from those years; or if I put on a resume what 

positions I had held during my organization years.  I said that 

if I went on a date and the woman of my dreams asked me where had 

I been all her life, I'd have to pay Scientology $50,000 if I 

dared to tell her.  I told Mr. Flynn that the requirements of 

non-amenability to service of process (Ex. C, 7H) and non-

cooperation with persons or organizations adverse to the 

organization (Ex. C, 7G, 10) were obstructive of justice.  I 

told him that I felt that agreeing to leave the organization's 

appeal of the decision in Armstrong I and not respond to any 

subsequent appeals (Ex. C, 4B) was unfair to the courts and all 

the people who had been helped by the decision.  I told Mr. Flynn 

that an affidavit the organization was demanding that I sign 

along with the settlement agreement was false.  The document 

stated, inter alia, that my disagreements with the organization 

had been with prior management and not with the then current 

leadership.  In fact there had been no management change and I 

had the same disagreements with the organization's "fair game" 

policies and actions, which had continued without change up to 

the time of the settlement.  I told Mr. Flynn that I was being 

asked to betray everything and everyone I had fought for against 

organization injustice.  It was as if no more restrictive, 

insulting, mean spirited, impossible and immoral an "agreement" 

could have possibly been "negotiated" on my behalf.

	26. 	In answer to my objections to the settlement agreement 

Mr. Flynn said that the silence and liquidated damages clauses, 

and anything which called for obstruction of justice were "not 

worth the paper they're printed on."  He said the same thing a 

number of times and a number of ways; e.g., that "you cannot 

contract away your Constitutional rights;" that "the conditions 

are unenforceable."  He said that he had advised the organization 

attorneys that those conditions in the settlement agreement were 

not worth the paper they were printed on, but that the 

organization, nevertheless, insisted on their inclusion in the 

settlement agreement and would not agree to any changes.  He 

pointed out the clauses concerning my release of all claims 

against the organization to date and its release of all claims 

against me to date (Ex. C, 1,4,5,6 and 8)and said that they 

were the essential elements of the settlement and "are what 

they're paying you for."

	27. 	Mr. Flynn also said that everyone was sick of the 

litigation and wanted to get on with their lives.  He said that 

he was sick of the litigation, the threats to him and his family 

and wanted out.  He said that as a part of the settlement he and 

all co-counsels had agreed to not become involved in 

organization-related litigation in the future.  He expressed a 

deep concern that the courts in this country cannot deal with the 

organization and its lawyers and their contemptuous abuse of the 

justice system.  He said that if I didn't sign the documents all 

I had to look forward to was more years of harassment and misery. 

 One of Mr. Flynn's other clients, who was in the room with us 

during this discussion, yelled at me, accusing me of killing the 

settlement for everyone, and that everyone else had signed or 

would sign, and everyone else wanted the settlement.  Mr. Flynn 

said that the organization would only settle with everyone 

together; otherwise there would be no settlement.  He did agree 

to ask the organization to include a clause in my settlement 

agreement allowing me to keep my creative works relating to L. 

Ron Hubbard or the organization (Ex. C, 7L).

	28. 	Mr. Flynn said that a major reason for the settlement's 

"global" form was to give the organization the opportunity to 

change its combative attitude and behavior by removing the threat 

he and his clients represented to it.  He stated that the 

organization had promised that if we settled they would cease all 

fair game.  He argued that the organization's willingness to pay 

us substantial sums of money, after its agents and attorneys had 

sworn for years to pay us "not one thin dime," was evidence of a 

philosophic shift within the organization.  I argued that the 

settlement agreement evidenced the unchanged philosophy of fair 

game, and that if the organization did not use the opportunity to 

transform its antisocial nature and actions toward its members, 

critics and society I would, a few years hence, because of my 

knowledge of organization fraud and fair game, be again embroiled 

in its litigation and targeted for extralegal attacks.

	29. 	Regarding the affidavit the organization required that 

I sign, Mr. Flynn said that the "disagreement with prior 

management" could be rationalized as being a disagreement with L. 

Ron Hubbard, and since Mr. Hubbard had died in January 1986 it 

could be said that I no longer had that disagreement.  Mr. Flynn 

said that the organization's attorneys had promised that the 

affidavit, which he said all the settling litigants were signing, 

would only be used by the organization if I began attacking it 

after the settlement, and since I had no intention of attacking 

the organization the affidavit would never see the light of day.

	30. 	During my meeting with Mr. Flynn in Los Angeles I found 

myself facing a dilemma which I reasoned through in this way.  If 

I refused to sign the settlement agreement and affidavit, all the 

other settling litigants, many of whom had been flown to Los 

Angeles in anticipation of a settlement, would be extremely 

disappointed and would continue to be subjected to organization 

harassment for an unknown period of time.  I had been positioned 

in the settlement drama as a deal-breaker and would undoubtedly 

lose the support of some if not all of these litigants, several 

of whom were key witnesses in my case against the organization.  

Although I was certain that Mr. Flynn and my other lawyers would 

not refuse to represent me if I did not sign the documents I also 

knew that they all would view me as a deal-breaker and they would 

be as disappointed as the other litigants in not ending the 

litigation they desperately wanted out of.  The prospect of 

continuing the litigation with unhappy and unwilling attorneys on 

my side, even though my cross-complaint was set for trial within 

three months, was distressing.  On the other hand, if I signed 

the documents, all my co-litigants, some of whom I knew to be in 

financial trouble, would be happy, the stress they felt would be 

reduced and they could get on with their lives.  Mr. Flynn and 

the other lawyers would be happy and the threat to them and their 

families would be removed.  The organization would have the 

opportunity they said they desired to clean up their act and 

start anew.  I would have the opportunity to get on with the next 

phase of my life and the financial wherewithal to do so.  I was 

also not unhappy to at that time not have to testify in all the 

litigation nor to respond to the media's frequent questions.  If 

the organization continued its fair game practices toward me I 

sensed that I might be left to defend myself and I accepted that 

fact.  So, armed with Mr. Flynn's advice that the conditions I 

found so offensive in the settlement agreement were not worth the 

paper they were printed on, and the knowledge that the 

organization's attorneys were also aware of that legal opinion, I 

put on a happy face and the following day went through the 

charade of a videotaped signing.  I believe I was guided by God 

in making the legally ill-advised decision to sign Scientology's 

documents.  This secret scheme to corrupt Justice is now seen as 

the evil it is in large part because of Scientology's insistence 

that Justice's corruption was its right.

	31.  It was my understanding and intention at the time of 

the settlement that I would honor in a sensible way the silence 

and confidentiality conditions of the settlement agreement.  I 

would not contact the media about Scientology, publish my 

Scientology history or file statements in court concerning 

Scientology.  It was also my understanding that the organization 

had agreed to do likewise; i.e., it would not contact the media 

about me, publish my Scientology history or file statements in 

court concerning me.  Although the "settlement agreement" did not 

specifically prohibit Scientology from communicating about me, it 

implied a reciprocality, and I knew that if it did communicate I 

would be free to respond.  That Scientology would be able to say 

whatever it wanted about me to the media, in publications, to 

governments, and in judicial or administrative proceedings, and 

could judicially prosecute me if I responded was, at that time 

and in this country, inconceivable to me.

	32. 	A few weeks after the "settlement" I was advised by a 

Los Angeles Times reporter that Scientology agents had delivered 

a stack of documents about me to the paper.  Although shocked by 

this action, which was out of the blue because I had said or done 

nothing about Scientology after the "settlement," I did not 

respond.  Following the settlement, and before I responded in any 

public way, Scientology subjected me to considerable fair game, 

which included filing affidavits falsely accusing me of crimes 

and of being an "agent provocateur of the United States 

government;" publishing distorted versions of my Scientology 

history; using documents which the organization had requested be 

sealed in Armstrong I to attack me; distributing dead agent packs 

of documents concerning me to the media; distributing copies of 

edited versions of the illegal videotapes of me to the media 

internationally; blackmail; and threatening me six times with 

being sued if I responded to any attacks.  Scientology also 

continued to subject other people to fair game, in violation of 

its promise through Mr. Flynn that it was ceasing all fair game 

activities.  The person who in the fall of 1987 delivered 

documents concerning me and a doctored and edited copy of the 

1984 illegal videotape of me to the London Sunday Times was 

Eugene Ingram. 

	33. 	For three years I attempted to live by the spirit of 

settlement, and, although threatened and saddened by 

Scientology's continuing attacks, did not respond, but had tried 

to live my life away from Scientology's war.  I wrote, drew, ran, 

had remarkable ideas, and formed The Gerald Armstrong Corporation 

("TGAC") with wonderful hopes and great expectations.  In late 

1989, however, after a series of threats from Scientology lawyer 

Lawrence Heller, following my being served with a deposition 

subpoena in the case of Bent Corydon v. Scientology, Los Angeles 

Superior Court No. C 694401, I concluded that I had to do 

something to defend myself.  I saw that I could not avoid a 

confrontation with the organization, and that there was a need to 

correct what I knew was as an obstruction of justice, that the 

settlement contracts and Scientology's enforcement thereof were 

working in the legal arena.  Mr. Heller threatened that if I 

testified about my knowledge of Hubbard and Scientology, even 

though I had been subpoenaed to testify, Scientology would 

consider such testimony a breach of the "contract" and would sue 

me.

	34. 	I researched my rights and responsibilities and 

concluded that I had a duty to oppose known obstruction of 

justice.  I also learned at that time that Scientology had been 

able to maintain an appeal from the Breckenridge decision in the 

California Court of Appeal and had just then filed its opening 

brief.  I therefore petitioned that Court to be able to file a 

response.  My filings in the Court of Appeal in 1990 included a 

declaration detailing and documenting Scientology's post-

settlement torts and violations, and a declaration detailing the 

circumstances at the time of the 1986 settlement.  The Court of 

Appeal granted my petition, I filed a respondent's brief, and in 

July, 1991 the Court affirmed the Breckenridge decision.  

Following the California Supreme Court's denial of review, 

Scientology filed a motion in the Court of Appeal to seal the 

record on appeal.  I opposed the motion, and the Court of Appeal 

denied it.  The complete trial transcript, which contains ten 

days of my testimony about my Scientology experiences up to 1984, 

is a public document.

	35. 	In August, 1990 I was greatly moved by the buildup 

toward war in the Middle East, and the general condition of man. 

 I prayed to God for guidance as to what I should do, and 

received the word: "Keep nothing.  Give what you have to the 

poor.  Take only what you need."  I gave my possessions to those 

whom I believed had a need for them as put in my heart by God, 

forgave debts owed to me, and determined to go where God would 

have me go and do what God would have me do; which I believed was 

to help where my help was asked for.  Although these decisions 

had nothing to do with Scientology, the organization has made 

them relevant in the legal arena by suing me and three of my 

friends, falsely charging that my giving away my things were 

"fraudulent conveyances" to make myself "judgment proof" so I 

could breach its "settlement agreement."  For the next year after 

my renunciation God had me, among other things, offer myself to 

resolve the Middle East conflict, do some house painting and 

carpentry work, deal with the pending appeal, attempt to correct 

Scientology's subversion of the legal system, agree to help the 

victims of Scientology who asked for my help, and offer myself to 

resolve the Scientology conflict in which I had been drawn by its 

attacks. 

	36. 	Scientology's fair game attacks on me following my 

responding in its appeal of the Breckenridge decision include, 

but are not limited to, secretly videotaping me; suing me and 

TGAC (pronounced "Teegeeack") four times (Marin Superior Court 

Case No. 152229, transferred to Los Angeles Superior Court and 

given No. BC 052395 ("Armstrong II"), Los Angeles Superior Court 

Case No. BC 084642 ("Armstrong III"), Marin Superior Court Case 

No. 157680 ("Armstrong IV," the "fraudulent conveyance" case), 

United States Bankruptcy Court for the Northern District of 

California Case No. 95-10911 aj, Adv. No. 95-1164 aj ("Armstrong 

V"); Armstrong II, III and IV were consolidated into Marin SC No. 

157680); attempting to have me jailed for contempt of court based 

on Scientology's misrepresentation of my actions and its own 

manufactured charges; filing declarations in various courts 

containing false charges, and using the "settlement agreement" to 

prevent me from responding or punish me for responding; using 

Eugene Ingram to spread the false rumor in 1992 that I have AIDS; 

forcing me into bankruptcy; attempting to seize my artwork, and 

personal and intellectual property through judicial means based 

on false charges; disseminating to the media packs of black PR 

which provide Scientology's false version of my experiences, 

including the lies that I testified falsely at trial in 1984; 

that I have "adopted a degraded lifestyle;" that I am connected 

to a referral agency for kidnapping; that my defense in the 1984 

trial was a sham and a fraud; that the Los Angeles Police 

Department authorized the illegal 1984 videotaping; that I wanted 

to plant fabricated documents in Scientology files and tell the 

IRS to conduct a raid; that I wanted to plunder Scientology for 

my own financial gain; that I never intended to stick to the 

terms of the "settlement contract;" that my motives are money and 

power; that I was incompetent as a researcher; that I perjured 

myself about surrendering documents to the court; that I wanted 

to orchestrate a coup in which members of the US government would 

wrest control of Scientology; publishing black propaganda about 

me without stating its source which provide Scientology's false 

version of my experiences including the lies that I was formerly 

a heavy drug pusher; that a Marin Independent Journal photo 

showed me in the nude; that I am psychotic and live in a delusory 

world; charging falsely in a letter to the press that I had 

distinguished myself by posing naked in a newspaper; attempting 

to cause me trouble with the IRS by writing black propaganda 

letters about me; distributing packs of black propaganda which 

attacked my lawyer 
Ford Greene, and Judge Breckenridge.

	37. 	I worked with attorney Greene from August, 1991 through 

December, 1995, except for about three weeks in April, 1995.  

Throughout that period Scientology attempted overtly through 

misuse of the courts and covertly through its Office of Special 

Affairs ("OSA"), the organization's intelligence arm, along with 

other operatives, to prevent me from working with Mr. Greene and 

from defending myself.  Scientology employed a covert operative, 

Garry Scarff, whom it had infiltrated into Mr. Greene's office, 

to develop a black PR "attack line" that Mr. Greene and I were 

involved in a homosexual relationship.  Scientology has subjected 

Mr. Greene to years of fair game, which included having Scarff, 

while in his office, steal his office records and cause trouble; 

concocting a plot with Scarff to have him killed; having Scarff 

execute false declarations about Mr. Greene; filing five spurious 

bar complaints against him; operating at least two of his 

clients, Richard and Vicki Aznaran, as Scientology's own agents, 

and paying them to execute false declarations against Mr. Greene 

and breach their contract with him.  Scientology was able to 

achieve one of its desired goals with the Thomas order, Ex. A, 

which made my working with Mr. Greene threatening and virtually 

impossible.  I have been denied two other good jobs in the past 

year because of my relationship to the Scientology organization 

and the threat that goes with it.  I have within the past week 

learned from Mr. Greene that his office was recently burglarized 

and my office file stolen along with other important legal files. 

 Eugene Ingram has been involved in the attacks on Mr. Greene, 

has harassed his friends, and sought by "legal" and illegal means 

to prevent him from effectively litigating against Scientology. 

	38. 	Throughout its post-settlement judicial attacks on me 

Scientology has proclaimed that by the "settlement agreement" it 

sought peace.  Scientology also interprets the "agreement" to 

mean that it can say whatever it wants about me, no matter how 

false, obnoxious or evil and that I may not respond.  The 

organization has indeed said whatever it wanted to about me, 

falsely accusing me of crimes and attacking my character and 

credibility.  Scientology claims that if I do respond in any way 

I am liable for $50,000 in liquidated damages, and may be jailed. 

 Scientology, under David Miscavige, has filed bogus lawsuits and 

been able to get Marin Superior Court Judge Gary W. Thomas for 

bogus reasons to give them an unreasonable interpretation of the 

agreement and an unreasonable judgment.  Judge Thomas has stated 

that essentially Scientology may say whatever it wants and I may 

not respond.  Because of, inter alia, what that kind of decision 

and reasoning portends for Lady Justice, and because the silence 

of bells too cannot be unrung, I have not succumbed quietly.

	39. 	Through the decade of Scientology's legal attacks on me 

after the December, 1986 "settlement," it has intimidated Mr. 

Flynn into not coming forward to assist me.  He was not only my 

attorney, he was my good friend.  He now says that the contract 

is evil, that Scientology is evil and he wants to help me.  He 

also says that he signed a "contract" with Scientology, which I 

was unaware of at the time of the "settlement," which 

specifically prevents him from assisting me.  While acknowledging 

that this "contract" is illegal, he says that he knows that his 

life will be ruined even more than it has been by Scientology if 

he comes forward to help.

	40. 	I believe that Scientology's interpretation of the 

"settlement agreement," to which Judge Thomas has added the 

authority of the California courts, is unconscionable and 

unamerican.  Because there are dozens of these "contracts" among 

first hand witnesses to Scientology's criminal and tortious 

practices, and because of Scientology's fair game use of the 

"settlement agreement" against me, I believe that a terrible 

injustice is being abetted by our courts, which should be opposed 

with all strength.  In my opinion, that one party to a settlement 

contract, which is supposed to be essentially a peace accord, is 

able to continue to shoot at the other party, who is wounded, has 

been disarmed and is not being allowed to defend himself in any 

way, is not peace at all but a demonic hunting trip.  The 

"settlement agreement," and now the judgment enforcing it, are in 

this "civilized society," licenses for hunting humans.

	41. 	I was paid in settlement by Scientology for its years 

of psychological cruelty, threat and stalking; i.e., fair game.  

Scientology's leaders did not learn their lesson but continued 

the cruelty, threat and stalking of a person already 

psychologically hurt and altered beyond belief by the actions 

they promised to cease.  I performed my part of the 1986 

settlement.  I dismissed my cross-complaint, released to 

Scientology all evidence from my case, removed myself from 

controversy, and gave Scientology the time and freedom it said it 

wanted to cease fair game.  Scientology's leaders, knowing that 

they had compromised and removed my attorney, failed to perform 

their part of the settlement, but continued fair game against me 

after they had psychologically wounded me and, they thought, 

rendered me defenseless.  

  	42. 	In 1991 I became a Christian.  I had, in the years 

after leaving Scientology, come to recognize that I was guided by 

God, and I sought to be guided in all circumstances in which I 

found myself.  Once its adherents become sufficiently 

brainwashed, Scientology does not permit them to believe in God, 

labels and treats anyone who believes in God as "psychotic," and 

enforces the satanic idea that God is an "implant," a false idea 

installed by pain and electronics in man's mind to enslave him.  

Scientology also teaches that Jesus Christ, the whole Gospel 

story, and Heaven are implants designed to enslave man, and that 

only Scientology has the way to free mankind from this 

enslavement.

	43. 	Scientology promotes to Christians and non-Christians 

that it is compatible with Christianity, that it holds the Judeo-

Christian Bible as a holy work, and that it has no argument with 

the belief that Jesus Christ was the Savior of Mankind and Son of 

God.  Scientology has distributed promotional materials 

containing these representations to every member of Congress, to 

libraries, to the media, to educators, to judges, and to people 

of influence across this country.  Scientology withholds from the 

public its actual enforced beliefs about God, Christ, Heaven and 

the Bible.  I believe this is religious fraud, and dangerous to 

everyone lured into Scientology, those already held by its 

brainwashing system, and society itself.  I also believe that 

Scientology's "creed" is a religious fraud because Scientology, 

under Hubbard's and Miscavige's control, has never acted in 

accord with it.  Scientology systematically abuses its members' 

civil rights, and seeks to destroy the same civil rights of its 

non-Scientologist "enemies."

	44. 	Scientology promotes actively and aggressively and uses 

the public postal system, public forums and public media for its 

promotions.  Scientology is a public figure.  It uses its 

resources to affect legislation and to violate people's civil 

rights.  Its efforts to judicially and extra-judicially silence 

and destroy me are clear examples.  I believe that this is not a 

legal purpose and not a purpose for which tax-exempt funds can 

legally be used.  I see that Scientology tricks and extorts huge 

sums of money from people it lures into its system for something 

of no value.  This money will be used to pay lawyers to attack 

the same people and those who seek to bring to light or curtail 

the abuse.  I have proof that Scientology obtained its tax-exempt 

status in 1993 by illegal means.  I believe that the Internal 

Revenue Service and the United States government agencies 

responsible were derelict in their duties in granting such tax 

exempt status. 

	45. 	The documents attached hereto as Exhibits E, F and G 

show Scientology's use of the "settlement agreement" to skew (and 

skewer) justice.  Exhibit E is a true and correct copy of a 

declaration executed February 8, 1994 by organization leader 

David Miscavige and filed in the case of Scientology v. Fishman 

and Geertz, US District Court for the Central District of 

California, Case No. CV 91-6426 HLH(Tx).  Mr. Miscavige devotes a 

paragraph to attacking and lying about me, although I had never 

up to that time filed any statement in the Fishman case.  (Ex. E, 

31:22-32:14)  In response to this attack and to provide the truth 

underlying Mr. Miscavige's false charges I filed in Fishman a 

declaration executed February 22, 1994, a true and correct copy 

of which, along with true and correct copies of the exhibits 

thereto, is attached hereto as Exhibit F.  Shortly thereafter 

Scientology moved to seal certain documents in the Fishman court 

file, one of which was my February 22 declaration.  In response 

and in opposition to this motion I wrote and filed a declaration 

executed April 21, 1994, a true and correct copy of which, 

without the exhibits thereto, is attached hereto as Exhibit G.  

Scientology sued me for these declarations, charging that they 

were "breaches" of its "settlement agreement," and claiming 

$50,000 liquidated damages for each.  My "voluntary assistance" 

to defendants Fishman and Geertz by way of these declarations is 

refered to in the Thomas order at Ex. A, 4:8-11.  Correcting of 

the Miscavige lies and preventing my own words from being sealed 

was impossible "involuntarily" because discovery was already 

closed in the Fishman case.  Even if discovery was still open 

there was not sufficient time to go through the ritual of being 

served, opposing Scientology's motions to prevent the deposition 

from going forward, combatting Scientology's obstructionist 

lawyers in deposition, and waiting for the deposition transcript. 

In my opinion, Mr. Ward is in a similar position: even if he 

could afford to pay a court reporter, there is not time enough to 

obtain the needed testimony before it is needed.  For this reason 

alone I believe non-assistance "contracts" such as those 

Scientology uses must be ruled illegal.

	46. 	That Scientology will move to block the depositions of 

people who signed its "settlement agreements" is shown by 

Scientology's "motion ... to delay or prevent the taking of 

certain third party depositions," a true and correct copy of 

which is attached hereto as Exhibit H.  Scientology filed this 

motion in the Corydon litigation after I was served in the case 

with a deposition subpoena.  The motion is based on a declaration 

by Scientology attorney Lawrence Heller executed November 1, 

1989, a true and correct copy of which is also attached hereto as 

part of Exhibit H.  In this declaration Mr. Heller states that 

"The non-disclosure obligations were a key part of the settlement 

agreements insisted upon by all parties involved."  (Ex. H, 9:5-

7) Mr. Heller also states in the memorandum of points and 

authorities: "One of the key ingredients to completeing these 

settlements, insisted upon by all parties involved was strict 

confidentiality respecting: ... any knowledge possessed by the 

Scientology entities concerning those staff members of 

parishioners."  (Ex. H, 4:9-14) Mr. Heller was of course lying, 

because Scientology had by then disseminated mountains of post-

settlement black PR about me possessed by the organization.  He 

was also lying about the reciprocality of the non-disclosure 

conditions because Scientology enforced its "settlement 

agreement" with me on that basis of its being able to say 

whatever it wanted about me but I must remain silent.  Judge 

Thomas's refusal to deal with or even acknowledge attorney 

Heller's lies and Scientology's inconsistent statements 

concerning reciprocality, even though these were carefully 

pointed out to him in my papers filed in the cases before him, I 

believe is an indicator of Scientology's corruption of the 

judicial process.

	47. 	That Scientology will also subvert our courts' power to 

prosecute "contempt" is shown in its "application for order to 

show cause why Gerald Armstrong should not be held in contempt," 

 filed December 31, 1992 in Armstrong II.  A true and correct 

copy of the application and Scientology's supporting documents is 

attached hereto as Exhibit I.  Scientology filed another 

application for an OSC re contempt shortly after this one, 

charging that my providing a declaration to Lawrence Wollersheim 

in the case of Scientology v. Wollersheim, Los Angeles Superior 

Court Case No. BC 074815, was a violation of its "injunction."  

Scientology's charges were either misrepresentations of my 

actions or completely manufactured.  Ultimately Judge Diane Wayne 

discharged all of Scientology's contempt charges in a ruling 

dated July 28, 1994, a true and correct copy of which is attached 

hereto as Exhibit J.  I do not believe I will receive equally 

fair treatment from Judge Thomas, and I am at great risk of 

Scientology being successful before him in its pressing to have 

me jailed.  I wrote a declaration in opposition to Scientology's 

contempt charges, and the organization deemed that declaration 

itself a violation of the "settlement agreement."  I do not have 

immediate access to that declaration, and many of my legal 

papers, but I will be able to provide it and any other documents 

in the near future if requested.  The documents I am attaching as 

exhibits to this declaration are a small fraction of the 

materials I have which show Scientology's malevolent side and its 

dedication to and employment of fair game.

	48. 	Attached hereto as Exhibit K is a true and correct copy 

of an article from the Boston Globe dated November 24, 1979 

concerning Scientology's fair gaming of writer Paulette Cooper, 

and mentioning other organization intelligence ops.

	49. 	Attached hereto as Exhibit L is a true and correct copy 

of a series of articles from the Oregonian dated from March 28, 

1985 through May 24, 1985 covering the trial of Julie 

Christofferson against Scientology in Portland, Oregon.  The 

April 5, 1985 article contains the statement concerning the 

illegally obtained videotapes of me: "'I think they are 

devastating, devastating against the church,' Multnomah Circuit 

Judge Donald H. Londer said."  The May 18, 1985 article announces 

the jury's award of thirty-nine million dollars to Ms. 

Christofferson.  

	50. 	Attached hereto as Exhibit M is a true and correct copy 

of an article from the Los Angeles Times announcing Judge 

Londer's declaring a mistrial, a month after the jury rendered 

its verdict.

	51. 	Attached hereto as Exhibit N is a true and correct copy 

of a series of articles from the Toronto Star and the Toronto Sun 

dated from March 12, 1992 through April 30, 1992 covering a $1.6 

million damage award to Crown Prosector Casey Hill whom 

Scientology and its lawyers libeled, and the trial of Scientology 

in Toronto, Canada for spying and theft.

	52. 	Attached hereto as Exhibit O is a true and correct copy 

of an article from the Denver Post dated November 23, 1996 

concerning the conviction of the head of Scientology in Lyon, 

France for subjecting a man to "psychological torture" resulting 

in his suicide.

	53. 	Attached hereto as Exhibit P is a true and correct copy 

of an article from the San Francisco Chronicle dated December 26, 

1996 concerning Germany's efforts to control Scientology's abuses 

and Scientology's attack on Germany.

	54. 	These articles, which are but a small fraction of the 

press around the world critical of Scientology, also support the 

invalidation of the Scientology's "settlement agreements" and the 

Thomas order.  It is entirely wrong that anyone be denied 

participation in a public controversy of this magnitude, a public 

controversy concerning national sovereignty and national security 

decisions.

	55. 	It is also wrong, and I believe constitutionally 

impermissible, to deny anyone freedom of religion by "contract" 

or court order.  The Thomas order prohibits me from "discussing 

... Scientology, the Church, and/or any of the Beneficiaries;" 

(Ex. A, 8:14-16)  If such a prohibition is legal concerning 

Scientology, a parallel prohibition would be legal concerning, 

for example, Christianity, God, and any religious experience of 

any kind.  The idea that this country's courts can give a 

"church" $50,000 in liquidated damages and send someone to jail 

for his discussing God or Christ or the Holy Scriptures, is of 

course absurd.  Who but evil itself would hatch such an idea?  

Scientology's "settlement agreement," its efforts to enforce, and 

the Thomas order are no less absurd, and no less evil's idea.  

Suppression of critics of a religion through judicial means is a 

violation of the Constitution's "Establishment Clause," and the 

Religious Freedom Restoration Act of 1993.  Michael Flynn did not 

have my permission to sell Scientology my freedom of religion 

(nor any of the other personal freedoms I possessed and enjoyed 

before the "settlement"), and even if I had given him such 

permission he could not sell it.  It cannot be sold.  Scientology 

couldn't buy it.  It cannot be bought.  Scientology claims it 

purchased my freedom of religion, in fact claims that it paid me 

eight hundred thousand dollars for it, but it could not have.  If 

it paid $800,000.00 for something it couldn't buy, receive or 

possess it paid way too much.  In reality, and I would think 

happily for Scientology, it received from me the dismissal of my 

cross-complaint, my accumulated evidence of its fraud and 

criminality, and my sincere efforts to let there be peace.  Thus 

it got a terrific deal, and its whining that I wouldn't sell what 

it couldn't buy is silly.

	56. 	Freedom of religion without freedom to discuss religion 

and religious experience is impossible.  Scientology insists that 

the world accept that it is a religion.  It asserts in its "bona 

fides," indeed in the submissions upon which it was able to get 

the US Government to give it tax-empt status, that it is 

organized solely for religious purposes.  The experiences of its 

members inside and in relationship to the organization, its 

founder, its "scriptures," its practices and its other members 

must therefore be religious experiences.  In my opinion, as long 

as Scientology maintains that it is a religion it cannot legally 

prohibit, by judicial means in this country's courts, anyone from 

discussing anything about it.  In my opinion, since Scientology 

insists on binding its members with "non-disclosure bonds" and 

similar "contracts," and binding its former members or targeted 

"enemies" with "settlement agreements" like Exhibit C hereto, it 

cannot be a religion; i.e., it cannot have it both ways.

	57. 	In my opinion, the exposing or dissemination of 

Scientology's "sacred scriptures," which is at issue in the Ward, 

Henson and Erlich cases, as well as in the Lerma and Factnet 

cases, is an analogous situation in which the same greater 

principle of religious freedom applies.  An entity which claims 

to have secret writings, which people to see must pay and agree 

to not discuss, cannot actually be a religion, because such a 

policy on its face restricts or prohibits religious expression.  

Such an entity can be a "secret-selling company," or some such, 

in competition with other secret-selling companies, as long as it 

does not try to claim that the secrets it sells are "religious" 

secrets.  Practically speaking, the only time this would become 

an issue is if an entity claiming to be a religion attempted to 

judicially prohibit the publication of its religious secrets or 

judicially punish their publishers.  Obviously people have the 

normal secrets that normal people have, and people talk about 

them and keep them or not, and so forth.  A real religion would 

have no reason to prevent the publication of its scriptures, and 

it would possess no "secret scriptures."  In my opinion, whoever 

has published Scientology's "secret scriptures" has in reality 

only been engaging in religious expression.  In my opinion this 

kind of expression is an expected, logical response to 

Scientology's efforts to corrupt the meaning of religion to 

"sanctify" its antisocial and dangerous mindset and criminal 

activities.  It is expression which cannot legally be prohibited 

or punished by judicial process.

	58. 	In my observation, Mr. Ward, Mr. Wollersheim, Mr. 

Henson, Mr. Erlich, Mr. Lerma and Mr. Penny (hereinafter, 

"WWHELP") are in general agreement that Scientology is not a 

sincere, and hence real, religion but is a criminal cult engaged 

in harmful practices.  In my opinion, if WWHELP are correct in 

their assessment, and if they did expose or publish Scientology's 

secret documents, they were and are completely justified in 

having done so.  It goes without saying that criminal cults, or 

any criminal enterprises for that matter, are against public 

policy.  It is certainly conceivable that writings which direct 

criminal cult members to think a certain way and perform certain 

acts in order to rise within the criminal cult's hierarchy, or 

become more criminal, are also against public policy.  In my 

opinion a reasonable person who has been presented with the facts 

about Scientology that each of the alleged publishers possessed 

at the time the publications were made would have believed that 

the prosecution of anyone pursuant to trade secret or copyright 

law for the publication of such writings is itself against public 

policy.  Thus Scientology's actual nature is relevant to WWHELP's 

defenses.  If Scientology is a religion, then WWHELP are 

justified in their religious expression.  In my opinion, for 

Scientology to now "become" a religion, among the other things it 

must do, it must cease its judicial persecution of anyone for his 

religious expression, even if that be criticism, publication or 

sworn testimony.  Scientology must otherwise, in my opinion, be 

seen as electing to remain a criminal cult, and must in these 

matters have our courts' ears shut to it, in limine.  

	59. 	This Court stated in its order dated January 6, 1997 

filed in the Erlich case:

	"The relevant inquiry is whether the documents for which 

trade secret protection is sought are "'generally known' to 

the relevant people -- the potential 'competitors' of the 

Church." [site] Nevertheless, defendant has not established 

the extent to which the specific processes and instructions 

contained in the works are known generally or to potential 

competitors. 

	nHow to identify "potential competitors" is a difficult 

question.  However, members of the newsgroup "alt.religion. 

scientology" might be considered as such." (Order, 21:10-14; 

n.17).

The identification of Scientology's "potential competitors" is 

actually not a difficult question.  In accordance with a long 

line of US Supreme Court cases touching on religious matters, a 

court's attempting to answer such a question would, however, be 

impermissible.  It is made "difficult" only because our courts do 

not generally, aside from rare anomalies such as "natural 

disasters," permit themselves to ascribe causation in human 

affairs to God.  The actions of Scientology, calling itself a 

religion and prosecuting religious expression in secular courts, 

now make answering this question in these courts possible and 

permissible.  In my opinion, Scientology's actual "competitors" 

are those whom God guides, those through whom He works to carry 

out His purposes.

	60. 	In the "religious realm," God's working in the lives of 

people, although, to those who understand it, infinitely more 

wonderful than any other conceivable possibility, is simply 

what's true, at least for someone.  This nation's courts have 

dealt with this truth by insisting that within the cases over 

which they preside the truth or falsity of religious beliefs will 

not be questioned; in this case, whether God indeed works in 

people's lives, and specifically whether God's guidance resulted 

in the exposing or publication of Scientology's "secret 

scriptures." 

	61. 	The guided come from any religion and from no religion. 

 They include those who seek God's guidance and those who don't 

seek His guidance, and may not even know or care that it is 

available.  Some people may know they're called to do God's work, 

and don't do it.  Some may not know they're called but do His 

work anyway.  This is easily understandable because God has given 

everyone a conscience and written His Laws on everyone's heart, 

whether they know it or accept it or not.  It is also easily 

understandable that the guided would be Scientology's natural 

"competitors" because Scientology has made a religion of 

nonguidance; and religion is a realm in which God observably has 

never let nonguidance triumph.  Although man may attempt to keep 

God out of his other realms, he cannot keep God out of religion, 

because in this world it is His Realm.

	62. 	Scientology does not acknowledge God's guidance, in 

fact teaches, despite its public relations to the contrary, that 

God does not exist.  In his bulletin dated May 11, 1963 entitled 

"Routine 3 Heaven," a true and correct copy of which is attached 

hereto as Exhibit Q, L. Ron Hubbard writes that Heaven, God and 

Christ are "implants," electronic mechanisms to entrap and 

enslave mankind.  These "religious" assertions are of course 

blasphemous. He writes moreover about the scientific nature of 

this "knowledge:"

	"This HCO Bulletin is based on over a thousand hours of 

research auditing, analyzing the facsimiles of the 

reactive mind, and with the help of a Mark V 

Electrometer.  It is scientific research and is not in 

any way based upon the mere opinion of the researcher. 

 This HCO Bulletin is not the result of the belief or 

beliefs of anyone.  Scientology data reflects long, 

arduous and painstaking research over a period of some 

thirty years into the nature of Man, the mind, the 

human spirit and its relationship to the physical 

universe.  The data and phenomena discovered in 

Scientology is common to all minds and all men and can 

be demonstrated on anyone.  Truth does not require 

belief to be true any more than water requires anyone's 

permission to run downhill.  The data is itself and can 

be duplicated by any honest researcher or 

practitioner."  (Ex. Q, at p. 4)

"Routine 3 Heaven" is considered by Scientology as part of its 

"confidential Church scriptures which are protected trade 

secrets."  I possessed this bulletin inside the organization, 

legally possess it now, and know personally at least a dozen 

other people who now possess it.  	

	63.	 In his bulletin dated September 23, 1968 entitled 

"Resistive Cases Former Therapy," a true and correct copy of 

which is attached hereto as Exhibit R, Mr. Hubbard writes that 

"the Christian Churches [ ] uses implanting."  He calls them 

"gangsters" who "invented Christ (who comes from the crucifixion 

in R6 75m years ago)(Hubbard's parens.) and implanted their way 

to "power"." (Ex. R. at p. 2).  This is also one of Scientology's 

"secret scriptures," which I and many other people legally 

possess.  It, like the rest of the organization's "secret 

scriptures," is an attack on Christianity, and blasphemous.    

	64. 	Scientology has its salvation "plan," its goal to 

"clear the planet."  It charges, even extorts, terrible sums of 

money, and lies to, cheats and bullies its adherents and targeted 

opposition.  Its guiding principle is fair game, its doctrine of 

opportunistic hatred, pursuant to which it uses the law to harass 

its targets.  God's plan on the other hand is free to everyone.  

He guides people to tell the truth and cheat and bully no one, 

but stand up to cheats and bullies, and stand up for their 

targets.  Scientology's leaders and God and His guided are 

"competitors" for human souls.  Scientology seeks to enslave 

souls, while God seeks only their freedom.  Other enslavers of 

the soul work through other cons appealing to greed, lust, fear, 

evil and the like.  They all lie.  No one is guided by God to 

bind human souls with "contracts" or threats which limit their 

expression.  No one is guided by God to hate, cheat or bully, or 

to use the law to harass.  God's guidance is wisdom.  

Scientology's guidance is stupidity; hence dangerous.  The 

exposing of dangerous cults masquerading as religions, and other 

enslavers, is a Biblically-blessed work of the guided.  Bringing 

Scientology's actual nature, a facet of which is reflected in its 

"secret scriptures," to light has arisen at this time because of 

a certain imminence.  The global nature of Scientology's threat 

to religion, and its menace to the minds of God's children at 

this time are observable factors.  It is altogether 

understandable that God would reach out through those who are 

available for His work in the realm of religion.  WWHELP have 

played God-given rolls in bringing Scientology's fraud and 

dangers to light, and they are a part of those God guides to such 

religious expression.  Some people testify, some picket, some 

encourage, some pray, some post their stories to ars.  These very 

cool spirits may or may not believe, sense or know they are 

guided by God.  One might think Christians would be the people 

most willing to speak out about Scientology and expose its 

"secret scriptures," because in the realm of religion the 

organization theologically is antichristian.  I have no reason to 

believe that any of WWHELP consider themselves Christians.  

WWHELP in fact may have thought they exposed Scientology's 

"secret scriptures," if they indeed did, for other reasons; e.g., 

that they showed it to be a criminal cult; that they are evidence 

of practicing medicine without a license; that the exposure might 

save someone from paying the criminal cult three hundred sixty 

thousand dollars to get to see.   In my opinion, they have done 

God's work.  Supporting that opinion is that fact that they 

published whatever they did without any intent to gain monetarily 

thereby.  A prophet brings God's message to His children, and 

cannot be silenced by our courts, even if he is a Prophet to 

Scientologists.

	65. 	Scientology claims to be prosecuting WWHELP for 

allegedly publishing its "secret scriptures," which includes the 

"OT materials," and the "NOTS materials."  To accomplish its 

raids and bring and maintain its lawsuits the organization has 

asserted that the OT and NOTS materials had been kept secret, and 

were not generally known except by its own adherents.  This is 

false.  I have possessed a copy of the OT materials for many 

years, and I know others who possessed these materials long 

before any of the internet publications.  During the Armstrong I 

litigation I possessed a copy of the complete set of NOTS 

materials, and I know several other people who possessed them 

long before any were published on the internet.  At the time of 

the Armstrong I "settlement" I delivered my copy of the NOTS 

materials to the Scientology organization.  This copy should be 

available to WWHELP through discovery in their cases.  In my 

opinion, Scientology's leaders have not brought these cases to 

protect the "secret scriptures," because they are not secret, but 

have used the law of trade secret and copyrights as an 

opportunity to harass available "targets," and thus send a brutal 

message to intimidate anyone whom God might call to stand up and 

speak free.

	66. 	Each of the WWHELP cases is being prosecuted by 

Scientology entity RTC, which claims to own the "religion's" 

marks, trade secrets and copyrighted materials.  RTC, operated by 

David Miscavige, is able to "legally" control the "religion," its 

operations, personnel, communication lines, finances, lawyers and 

agents because of this claimed ownership.  In my opinion RTC did 

not obtain this claimed ownership by legal means, and now 

maintains such illegally ownership to the detriment of the 

practitioners of the "religion" and society at large.  It is my 

understanding that David Miscavige notorized the signature of L. 

Ron Hubbard near the time of his alleged death in 1986 on a 

document which transfered Mr. Hubbard's ownership of certain 

rights and/or marks from himself to RTC.  While on board the 

"Apollo" during 1972 through 1974 I was required on a number of 

occasions to have Mr. Hubbard's signature notarized on various 

documents.  There were a couple of notaries in Portugal I got to 

know who would verify the signature by comparison with a 

signature in their signature book.  There were times when I took 

documents to these notaries which were not signed by Mr. Hubbard, 

but by Joyce Popham, who could sign his signature extremely well. 

 Two of the documents signed by Ms. Popham were for the 

registration of the marks "Dianetics" and "Scientology."  The 

forging of signatures or obtaining false notarizations is not 

unreasonable in Scientology affairs.  There is as well the more 

serious question of Mr. Hubbard's actually not owing or 

possessing the rights RTC says it acquired from him.

	67. 	Attached hereto as Exhibit S is a true and correct copy 

of three documents I received in late November, 1996 from Craig 

Branch of the Watchman Fellowship, a Christian research and 

apologetics organization and publisher.  The first document is an 

undated letter to me from Mr. Branch.  The second is a letter 

dated October 21, 1996 from Cathy Norman of Scientology's Office 

of Special Affairs in Austin, Texas.  The third document is black 

PR on me in the form of a standard "DA document."  It repeats the 

same lies David Miscavige put in his declaration (Ex. E).  See, 

e.g., Ex. S, DA Doc, at p. 4 where Scientology asserts that "the 

Church obtained permission from the Los Angeles Police Department 

to conduct undercover surveillance of Armstrong, and compare with 

Ex. F, and the attached public announcement of then LAPD Chief 

Daryl Gates.  According to Scientology I cannot respond to 

correct the lies in this latest example of Scientology's black PR 

to reach me, in this case sent to a prominent person in the 

Christian community.  Scientology is attempting with this sort of 

attack, coupled with its "non-disclosure" contracts and orders, 

its glossy PR, legal triumphs, etc. to rewrite history.  I 

believe Scientology's efforts to rewrite history are dangerous, 

and my silence only abets the threat.  In my opinion, Scientology 

can never rewrite history, and it is well advised to give up the 

effort and instead through honest change become the honest 

organization it now tries dishonestly to get the world to believe 

it is.

 	68. 	On January 23, 1997 I received in the mail from Grady Ward a subpoena, a true and correct copy of which is attached 

hereto as Exhibit T, for production of documents in his case.

	69. 	On January 24 I received from attorney Andrew H. Wilson 

a fax letter, a true and correct copy of which is attached hereto 

as Exhibit U, threatening prosecution in Armstrong IV if I 

provide documents to Mr. Ward pursuant to his subpoena.  This 

letter is frightening to me, and supports why I am sending this 

declaration directly to the Court, and why the "settlement 

agreement" and the Thomas order are illegal.  Mr. Ward does not 

have the time to wait for my testimony until Scientology's motion 

for protective order is heard before he must file this testimony. 

 In my opinion, that is precisely why Mr. Wilson has sent his 

threat letter.  Scientology already enjoys a terribly uneven 

playing field in its cases against WWHELP, especially against Mr. 

Ward and Mr. Henson, who are proceeding unfinanced and undefended 

by lawyers.  We're kindred souls.  Scientology spends millions on 

lawyers and more millions on private investigators.  Its history 

of attacks on judges and efforts to compromise judges was known 

to me inside the organization, and I have learned more about this 

evil since leaving.  Scientology's personnel are trained to lie, 

and its lawyers paid to lie.  It has a policy and history of 

destruction of evidence (See, e.g., Ex. D).  It seizes every 

advantage our country's laws confer on religions and does not 

perform its responsibilities as a religion.  It keeps witnesses 

with material evidence bound and intimidated by illegal "non-

assistance" contracts and other threats.  Other people who have 

testimony regarding Scientology's nature, structure, history, 

"scriptures," and practices, who I know or have been so informed, 

to also be bound by Scientology's "contracts," include, at least: 

Laurel Sullivan, William Franks, Howard Schomer, Martin Samuels, 

Michael Flynn, Esq., Julia Dragojevic, Esq., Garry P. McMurry, 

Esq., Gabe Cazares, Bent Corydon, Michael Douglas, Kima Douglas, 

Nancy Dincalci, Edward Walters, Julie Christofferson, Nancy 

McLean, John McLean, Warren Friske, Robert Dardano, Tonja Burden, 

Margery Wakefield, Paulette Cooper, David Mayo.  In my opinion, 

Scientology steps so brazenly into court and sues so wantonly 

because it believes it has so many people bound to silence that 

it can lie with impunity.

	70. 	Mr. Ward, and indeed all of WWHELP, should be able to 

freely obtain the testimony of anyone willing to testify on their 

behalf, or by subpoena anyone unwilling.  They should be able to 

obtain the assistance of any expert witness they believe can 

help.  Because Scientology has so distorted the floor of the 

legal arena I am moved to seek guidance in how to help.  No 

person, seeking and knowing God's guidance, would not help.  I 

have a personal interest in the outcome of all of Scientology's 

cases, because an outcome favorable to the organization will be 

used to attack me and my friends.

	71. 	If it is within this Court's power, and I believe it 

is, I ask that it issue an order prohibiting Scientology from 

interfering with Mr. Ward's, Mr. Henson's and Mr. Erlich's 

witnesses, including me, and an order to Scientology to release 

me from its "contract" and the Thomas order so that I am free to 

assist these defendants in their cases.

	I declare under the penalty of perjury under the laws of the 

State of California that the foregoing is true and correct.

	Executed at San Anselmo, California, on January 26, 1997

					                                      

							GERALD ARMSTRONG

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