Donald C. Randolph

Donald C. Randolph

Donald C. Randolph

Declaration of Gerald Armstrong (November 18, 1986)



I, GERALD ARMSTRONG, declare as follows:

1) I have been advised by my attorney, Julia Dragojevic, that cross-defendant organization has moved to continue the trial of the cross-complaint, now set for January 19, 1987. The organization has offered three reasons for its motion: A) it was not aware of a “brainwashing” claim until it got my response to its motion for summary adjudication on the application of statutes of limitation to the pc file issue; B) it wants to first get the Appeals Court decision in the document
case; C) it needs more time for discovery. 2) “Brainwashing” is the organization’s term. It cannot profess ignorance of the subject as L. Ron Hubbard wrote as early as 1956 in a “Technical Bulletin” attached hereto as Exhibit A:

“We (Scientology) know more about psychiatry than psychiatrists. We can brainwash faster than the Russians (20 secs to total amnesia against three years to slightly confused loyalty).”

And the organization cannot honestly claim that any mention by me of Hubbardian or organization mind control is a new surprise. Attached hereto as Exhibit B are two pages from a declaration I filed in 1982 in which I state: “What most Scientologists, and especially Sea Org members don’t know is that Mr. Hubbard had duped


them. My knowledge based on documentation and observation, is that the major reason for Mr. Hubbard’s calling Scientology a ‘religion,’ in addition to tax evasion, is to hide behind Constitutional guarantees for religions and so carry out his scheme of mind control to keep his followers duped. He has systematically and knowingly lied to and defrauded his followers, kept them from finding out the truth or becoming free with cruel and bizarre treatment, as for example with the RPF, and kept them economically and mentally suppressed, while he made millions of dollars from their labor.”

The Court touched on mind control in the decision in the document case:

….the Church or its minions is fully capable of intimidation or other physical of psychological abuse if it suits their ends. The record is replete with evidence of such abuse.”

And common sense yields only mind control as the explanation for the years of submission to the abuse. The organization has known of its own practices for decades, has known for over four years that I defined some of those practices as mind control, and has known for over two years that the Court considered “psychological abuse” and Hubbard’s “controlling, manipulating….his adherents” part of this case. Mind control is not a new subject which would require of the organization a new defense or more time in which


to create it.

3) Regarding continuing the trial of the cross-complaint until issuance of the Appeals Court decision in the document case, it was cross-defendant organization which moved to sever the cross-complaint as unrelated to the underlying document case.

4) In the document case, for a trial that lasted thirty days, because the organization insisted on an expedited trial, I had twenty months in which to prepare for my defense. From the time of filing of the cross-complaint until the present trial date, the organization will have had fifty months. The organization has taken my deposition at least twenty-five days, and has taken the deposition of virtually everyone connected to me at some point in this litigation. Each person on this side whom the organization has sought to depose has complied and has answered any relevant questions. My attorneys advise me that because of the organization’s compartmentalization and obstructionist tactics, taking any organization depositions is a costly and frustrating waste of time. The organization knows virtually ever fact of my life since I was born which has any connection at all to the issues in the cross-complaint; there is nothing left to discover. Discovery by the organization is for this reason, and because of attorney tactics and behavior, largely harassive. The extension of discovery is just the extension of harassment.


5) The organization cannot honestly argue that it was prevented in any way from getting whatever discovery it has wanted or from getting its many motions, several of which were in fact obstructive of legitimate discovery, heard by this Court. The organization has used 12 law firms in this case, and these attorneys have all been involved in other Scientology litigation and have deposed all my potential witnesses in those cases in addition to this. In addition to the staggering sums paid to attorneys to litigate this case, the organization has paid at least hundreds of thousands of dollars for PI’s, for intelligence operations and for media black PR campaigns against me. Where it could not wait for legal discovery, it stole my documents. And as shown in my earlier declarations, it has, through perjury and manipulation, thwarted my discovery into its clear cut and egregious invasions of my privacy and assaults on my mind.

6) The organization has demonstrated continually throughout the litigation of this case that truth, which must have some relationship to legitimate discovery, is, as far as the organization is concerned, irrelevant. Attached hereto as Exhibit C is a copy of a recitation of a dream I had in March 1985. I have blacked out for this purpose, anything which could be considered offensive. Donald Randolph has, in furtherance of the organization’s goals, defined the recitation of the dream a “sickening work” demonstrating my “extremely aberrated activities.” The dream was a dream. The recitation was true, and as artistically tight as I was capable of. To the


organization, if it suits its purposes, however, dreams are reality, and truth is whatever can be twisted therefrom. The only thing “sickening” about the dream is how the organization acquired it and went about its degradation. I sent it to my friend Dan Sherman, a professional writer who had throughout 1984 encouraged me to write and who had “critiqued” some of my work. Sherman was, of course, being operated by the organization in the “Armstrong operation” (the same operation which John Peterson says never happened), and Sherman either gave the organization the “dream” he had dutifully tricked me into sending him, or the organization simply stole it from him. Attached hereto as Exhibit D is a letter from Sherman from March 1986 in which he indicates that the organization was indeed getting his mail. Since writing to me, however, Sherman has apparently again been pressured by the organization because he has again cut communication with me and gone into hiding.

Another example of organizational perversion of truth is the whole Armstrong operation. A group of individuals fearing for their lives and asking me for help to reform the organization became in organization black PR campaigns my attempt to destroy religion. Efforts by the organization to enveigle me into illegal acts became my commission of the acts. Use of my pc files as a lure to entrap and ruin me is characterized as protecting the sanctity of auditing. The organization needs no more discovery since it creates “truth” and “evidence,” as it wishes.


7) All the discovery the organization has sought can be completed in the next two. weeks. I have been answering interrogatories, in addition to all the other work I must still do, and despite the fact that none of the interrogatories cover anything which I have not already testified about, and I will complete them by November 26, 1986. The organization took my deposition on October 29 and 30 and they can have my deposition another day before trial if they want. They have made no request to set a date for the continuation of my deposition since the two days in October. The organization, just to delay the trial, should not be permitted to delay the discovery opportunities it has.

8) Although the organization is clearly not harmed if the cross-complaint goes to trial January 19, I will be if it doesn’t. Through all the operations, the lies and attacks over more than four years, the hope of going to trial has been a major stabilizing factor in keeping me going. I do not have the extra legal options which the organization does; my only opportunity to resolve this protracted, bitter and emotionally devastating war is at trial. My life has been radically altered by the organization’s acts: the threats, the assaults, the pc file perversions, the obstruction, the lies, the operations, the betrayals, the terror. The intensity has fluctuated and there were brief periods when my life moved toward normalization, but always briefly as another organization attack was never far away.


Since the July pc file culling, however, there has been no respite. The anguish I feel just about every day may be a blessing because the emotional ripple does not manifest itself in other more destructive ways. But I cannot feel that it is optimum or normal or healthy; that is, I’m under a ton of stress. I have grappled with the litigation and the extra-litigation threat in many ways. Some of them, even within the observable context of Gerald Armstrong, and even to myself, are bizarre.

Almost the whole day now, and day after day, is connected to this subject. Sometimes I feel like my body is a battleground. Outside my apartment and office, and those are just about all my destinations, I am most of the time aware of the cold evaluation of threat. I am intellectually sound enough to realize that to succeed in getting the cross-complaint to trial raises the potential for a really serious operation. The emotional ramifications which follow from that are what I deal with. That is, the alteration of the circuitry. The lessening of the threat can only be achieved, however, by going forward, even though what could happen at trial could be beyond anything I’ve yet experienced. All the operations have had the ultimate goal of stopping me from proceeding to trial. They have only succeeded in convincing me that the only way the war and the threat can end is to get to trial.

Executed this 18th day of November, 1986 at Boston, Massachusetts.

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



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Impact: on Scientology litigation, Earle Cooley, Don Randolph, Ken Hoden. (1985)

IASA (1985). Fighting Back: The Third in the Series Handling Attacks. Impact 3, 44.) 1


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OSA Press Release (October 23, 1984)

Source  “PR Newswire”
Author  Sanford Block
Date  October 23rd, 19841

LOS ANGELES, Oct. 23/PRN – A lawsuit seeking more than $ 20 million in damages
was filed today in Los Angeles Federal Court by two churches of Scientology, charging
that Boxford, Mass., lawyer Michael Flynn; his brother Kevin Flynn; his partner, lawyer
Thomas  Hoffman;  and  other  defendants  conspired  to  violate  the  civil  rights  of  the
churches, according to church attorney Donald C. Randolph.

Randolph charged that the defendants engaged in a “malicious conspiracy” against the
Church of Scientology. Randolph said this included:

– the unlawful communication of knowingly false or misleading information to state and
federal law enforcement agencies;

– numerous false statements against the churches in lawsuits throughout the country; and

– an extensive media campaign to disseminate false information about the churches.

The complaint also alleges that the defendants boasted “of their coordination and close
relationships” with government agents in carrying out their personal vendetta against the

These agents include representatives of the IRS, the FBI, and the Department of Justice,
who have all been involved in litigation with the church for almost a decade, Randolph

The suit, filed in the U.S. District Court for the Central District of California, asks for
more than $10 million in 9 compensatory damages and $10 million in punitive damages,
Randolph said. The claims were brought based on alleged violations of the Civil Rights
Act of 1871, he continued.

The  churches’  48-page  complaint  details  what  Randolph  described  as  “an  ongoing
conspiracy, stretching back at last five years.”

Randolph added that “the nature and extent of the conspiracy is documented in full detail
in  papers  regarding  ‘Famco’  (Flynn  Associates  Management  Corp.),  a  corporation
created by the conspirators to forward their campaign and in numerous other documents,
as well as eyewitness accounts.”

Randolph said, “This broad-based conspiracy undertook to purposely manipulate the state
through unlawful activities and ultimately to destroy a religion.”

Randolph said: “This lawsuit is important for the preservation of religious freedom, not
only for the Scientologists but for people of all faiths who cherish their right to exist and
worship  without  unlawful  interference.  This  action seeks to terminate  the  antireligious
activities and to send a warning to their imitators.”

Contact – Donald C. Randolph or Sanford Block at 213-474-6020 and 213-662-9431 for
the Church of Scientology.


OSA Press Release (August 1, 1984)

Author  Sylvia Stanard
Date  August 1st, 19841

WASHINGTON, July 31/PRN – House and Senate oversight committees are being asked
to investigate the refusal of Small Business Administration officials to probe allegations
that  some  investors  in  a  new  Washington  restaurant  may  be  connected  to  narcotics
trafficking,  according  to  the  Church  of  Scientology’s  Washington  attorney,  Robert  L.

Oswald said that the alleged drug connection was recently discovered during a probe into
an attempt to pass a counterfeit forged $2 million check against the personal account of
Scientology founder L. Ron Hubbard.

Oswald said investigators obtained a signed declaration from a former employee of the
bank  that  said  he  had  seen  Kevin  Flynn,  an  officer  of  General  Business  Management
Corp., in the high-security section of the Bank of New England in Boston, where checks
were allegedly stolen from Hubbard’s account for counterfeiting in 1982.

Oswald added that Flynn disappeared when the counterfeit attempt failed and resurfaced
a year later in Washington, seeking the SBA loan.

Oswald  said  that  the  investigation  of  the  financing  of  the  Washington  restaurant  –
Blossoms – led the investigators to:

– Paul Flynn, cousin of Kevin Flynn, who Oswald said is an imprisoned drug smuggler
who raised cash for Blossoms;

– Paul Flynn’s Florida attorney, Rex Ryland, who Oswald said was recently indicted in
U.S. District Court as the ringleader of a major drug-smuggling operation throughout the
United States.

–  Two  individuals  who  Oswald  said  invested  in  Blossoms  and  whom  he  described  as
having close ties to narcotics smugglers in California and Florida.

– Michael Flynn, Kevin’s brother, who allegedly orchestrated the $2 million forged check
using Boston organized crime figures, according to sworn declarations – submitted last
week to a Los Angeles federal court, and now in federal hands – by those who worked
with him on the alleged conspiracy. – Alleged misrepresentations to the SBA – detailed in Los Angeles federal court affidavits
submitted by civil rights attorney Don Randolph last week – by Kevin Flynn’s Boston
attorney Tom Hoffman that Kevin Flynn was not a defendant in any suit.

Flynn was allegedly being sued in two separate cases in California and Boston for false
imprisonment and kidnapping.

“The investigators are seeking the assistance of congressional oversight committees after
SBA officials who were given information about the loan misrepresentations refused to
pursue the matter,” Oswald said.

According to the church attorney, the $2 million check forgery was attempted in 1982
and then used by Boston attorney Michael Flynn later that year to argue that Hubbard’s
estate was being mismanaged and should be seized by a Riverside court.

Flynn brought the probate suit in 1982, representing Hubbard’s estranged son, Ronald E.
DeWolf.  Oswald noted that “the petition was thrown out of court a year later.”

Rev. Heber Jentzsch, president of the Church of Scientology International, said, “It will
take  the  full  resources  of  the  government  to  expose  why  the  SBA  granted  a  loan  on
deliberate false information and why Kevin Flynn withheld the information that he paid
known kidnappers to terrorize people for their religious beliefs.

Contact – Robert L. Oswald at 202-293-3204, Nick Beltrante at 703-360-4848, or Sylvia
Stanard at 202-797-9828, all of the Church of Scientology.


OSA Press Release (July 24, 1984)

Source  “PR Newswire”
Author  Heber Jentzsch
Date  July 24th, 19841

LOS ANGELES, July 24/PRN – Federal investigators are in possession of documentation
allegedly detailing a criminal conspiracy to loot the personal estate of best-selling author
and Scientology founder L. Ron Hubbard with a counterfeit and forged $2 million check.

The  declaration  was  filed  in  a  Los  Angeles  federal  court  and  released  at  a  news
conference  today  by  noted  civil  rights  attorney  Donald  C.  Randolph,  the  Church  of
Scientology reported.

The check was then used in the sensational Riverside, Calif., probate case in an aborted
attempt to seize control of the legendary writer’s estate, the church said.

According  to  these  documented  eyewitness  accounts,  Randolph  told  the  U.S.  District
Court that Boston personal injury attorney Michael Flynn, long-time critic of the church,
secretly hired a forger to pass a counterfeit $2 million check against Hubbard’s account,
the church reported.

Randolph  charged  that  Flynn  then  used  his  own  felony  to  initiate  the  sensationalized
1982 probate case brought by Hubbard’s estranged son, Ronald E. DeWolf, to argue that
the best-selling author’s estate was in jeopardy and should be seized.

The  attempt,  failed,  however,  when  the  court  threw  Flynn’s  case  out  and  ordered
DeWolf,  a  50-year-old  Nevada  apartment  house  manager,  to  pay  all  costs.  Flynn  was
found  in  contempt  of  court  during  the  proceeding  for  violating  court  instructions,  the
church reported.

To  finance  his  attack,  according  to  Randolph,  Flynn  created  Flynn  Associates  and
Management Co. (FAMCO) and tried to sell shares on the promise that profit would be
made  by  capturing  Hubbard’s  estate  through  a  series  of  “frivolous  suits”  designed  to
generate  so  much  “adverse  publicity”  against  Scientoloy  and  Hubbard  that  the  church
would be forced to settle for millions of dollars, the church claimed.

The forgery and probate scheme, Randolph said, was but one part of the Flynn conspiracy
now in the hands of several federal agencies.

Randolph disclosed details of the check forgery scheme in papers filed in a suit brought
against Flynn’s brother, Kevin, and FAMCO in Central District Court for violating the civil
rights of Scientologist Steve Miller of Los Angeles. Flynn is an officer and director

Randolph said that after gaining access to the Bank of New England, where Hubbard had
an  account,  Flynn  illegally  obtained  sample  checks  and  then  hired  Ala  Tamimi  –  who
Randolph claimed was a known forger, living in Boston – to counterfeit and forge a $2
million check on Hubbard’s account at the Bank of New England in Boston.

Church attorneys also cited newspaper accounts describing the involvement of the same
Bank of New England in another $2 million forgery case where a contact inside the bank
made  confidential  information  available  to  a  disbarred  Boston-area  attorney  in  a  gem

In a signed, fingerprinted and notarized declaration given in Italy and witnessed by his
attorney – now in the possession of federal prosecutors – Tamimi related how Flynn had
promised him $400,000 to pass the check and transfer the $2 million from the account of
the legendary writer to an overseas account that Flynn would later designate.

Tamimi  then  used  his  brother  Akil  to  try  and  cash  the  forged  check  in  New  York.
Randolph said that according to his own sworn statement, also in federal hands, Akil was
very nervous during his visit to the bank, failed to produce proper identification papers,
and  left  the  $2  million  check  at  the  bank,  saying  he  would  return  with  proper
identification the following day.

Flynn’s plot was thwarted, according to the Randolph affidavit, when Akil panicked and
failed to return. Meanwhile, Hubbard’s business managers learned about the check and
quickly alerted the bank to stop payment. Tamimi fled the country while his brother Akil
disappeared  into  Maine  with  the  help  of  one  of  Flynn’s  men,  according  to  the  filed

Randolph told the court that Flynn later used his own aborted plan to file the California
probate petition with DeWolf in 1982, when he tried to shift the blame for the crime to
Scientologists, claiming it proved that Hubbard’s estate should be seized by the court in
order to allegedly protect it from Scientologists.

Church of Scientology attorney John Peterson stated that a portion of the results of the
international inquiry were made available to Randolph and his client when Kevin Flynn
attacked the church in the Miller case.

According to Peterson, the affidavits “are but one small part of the evidence collected and
turned over to federal officials. We have eyewitnesses, documents and photographs that
leave not one shred of doubt.”

Peterson noted that the investigation of the criminal conspiracy to loot Hubbard’s estate
was  initiated  earlier  this  year  with  a  series  of  full-page  ads  in  a  number  of  national
newspapers,  including  the  New  York  Times,  the  Boston  Globe  and  the  Wall  Street
Journal,  offering  a  $100,000  reward  for  information  about  the  forged  check.  “Private
investigators operating in four countries from subsequent leads finally uncovered Flynn’s
conspiracy,” the church attorney said.

Peterson  added  that  Flynn  was  an  unknown  personal-injury  attorney  until  he  tapped
Hubbard’s popularity, and that he “had earlier demanded that the church pay him $1.6
million to stop suing the organization. When the church refused to pay, Flynn devised
and carried out the forgery plot and the probate petition to plunder Hubbard’s estate.

Contact – Heber Jentzsch of the Church of Scientology at 213-666-5570, or John Peterson
or Donald C. Randolph at 213-659-9965 and 213-474-6020, respectively, for the Church
of Scientology.


Los Angeles Times: Scientologists Blame Mystery Forgery Try on Lawyer-Critic (July 24, 1984)

Scientologists Blame Mystery Forgery Try on Lawyer-Critic1

Church of Scientology officials Monday accused a Boston lawyer who has been a prominent critic of the organization of conspiring to pass a counterfeit $2-million check on the account of Scientology founder L. Ron Hubbard and later blaming the forgery on members of the church as part of an “overall plan” to destroy the group.

The charges were made against attorney Michael Flynn in documents filed in Los Angeles federal court in connection, with a lawsuit filed by a Scientology member, Steve Miller, accusing the lawyer’s brother, Kevin Flynn, of kidnaping him three years ago and attempting to “deprogram” him.

Michael Flynn, who has filed 20 lawsuits against the Church of Scientology, angrily denied the charge and said it was a “typical” Scientology tactic to try to smear critics of the organization.

“There is not an ounce of truth in this story,” Michael Flynn said. “This is a conspiracy to frame me. It’s absurd; it’s a joke. I am not a forger. I’m going to file a criminal complaint against them for this. Somebody going to pay.”

Two-Year Investigation

The Rev. Heber C. Jentzsch, president of the Church of Scientology International, said the accusation against Michael Flynn was made after a two-year investigation into the mysterious forgery attempt in response to renewed claims by Flynn’s brother last week that the alleged crime had been carried out by “Scientology insiders” who had access to Hubbard’s personal financial records.

“We’re clean. We’ve cleaned out that whole house in the last seven years,” said Jentzsch, referring to past legal problems involving the organization, including FBI charges that the group had infiltrated government agencies and stolen government documents pertaining to the church. “They keep making the allegations about us, but we have the documents.”

Donald C. Randolph, a Los Angeles attorney representing Miller in the suit against Flynn’s brother, said the investigation into the Boston lawyer’s activities by the Church of Scientology focused on the testimony of two men who said they had conspired with Flynn to pass the counterfeit check.

The two men were identified as Ala Fadili Al Tamimi, a former resident of Boston currently in jail in Italy awaiting extradition to the United States in connection with another fraud case, and Tamimi’s brother, Akil, now a resident of Sharjeh in the United Arab Emirates.

Tamimi alleged in a declaration cited in the court records that he met with Flynn in early 1982 and was promised $400,000 to pass the check. He used his brother, Akil, to try to cash the counterfeit check in early 1982 at the Middle East Bank in New York, the declaration said.

Suspecting that something was wrong, officials of the bank raised questions about the check and it was not cashed. In previous court cases against the Church of Scientology, there have been references to the check and suggestions that the counterfeit attempt revealed a plot by Scientology officials to “loot” Hubbard’s personal bank accounts.

Hubbard has not been seen in public since 1980. In June, 1983, a Riverside Superior Court judge dismissed a suit by Hubbard’s estranged son that claimed his father was either dead or incompetent. A declaration signed by Hubbard introduced as evidence at that trial said that Hubbard was in seclusion by his own choosing. His estranged son, Ron DeWolf, had filed a probate petition.

In the documents filed Monday, Randolph said the DeWolf probate petition was based in part on Flynn’s accusations that the attempt to pass the $2-million counterfeit check had been made by church members.

“This type of accusation constitutes a classic example of the criminal accusing others of his own crime to divert attention from himself,” the affidavit said. “In essence, attorney Michael Flynn orchestrated a conspiracy to break the law, then utilized the thwarted attempt as false evidence in subsequent court proceedings.”

Flynn, reached by telephone in Boston, predicted that Randolph’s charges, contained in a motion to dismiss his brother’s previous claims of Church of Scientology harassment, would be dismissed by U.S. District Judge Francis C. Whelan.

The deprogramming case involving Flynn’s brother is in an early stage, with no trial date yet set. The private investigator who brought the charges against Flynn is Eugene M. Ingram, a former Los Angeles Police Department sergeant. Ingram was fired in 1981 from the LAPD on departmental charges of helping run a house of prostitution and protecting drug dealers. Criminal charges were dismissed the following year, however, for lack of evidence.


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