GA Letter to Jesse Prince (November 14, 2014)

Dear Jesse:

In my November 9 communication1, I mentioned that I would deal later with fact errors about me in your article,2 and I’m doing so now. I excerpted the section of the article that concerns me, and commented where I thought correction or clarification was needed.

JP: I began to recall being on the other side of the fence when Gerry Armstrong had to defend himself against Scientology style black ops for years.

What I had to defend against was war. It is understandable that the Scientologists waged Scientology style war; but because it is solely Scientologists, and their mercenaries, of course, who are waging it, and all in the cause of Scientology and in application of Scientology scriptural directives, it is proper to call what I had to defend against “war,” the Scientologists’ war on me.

Black ops are an essential option and channel in the Scientologists’ war machine. Again, because the Scientologists are the entities running the black ops, they’re properly Scientology black ops, rather than Scientology style black ops. If the Catholic Church has a war machine, and its black ops department got a writer’s finger prints on a sheet of paper and sent a threat letter to the Pope to get her falsely charged criminally, that would be a Scientology style black op. Or if the Catholic Church’s black ops department, with the Pope’s blessing and guidance, trained and drilled a priest to get close to some guy by pretending to be friendly, truthful and loving but really being an enemy, lying to the guy, covertly hostile to him and working for his destruction; then the priest and the Pope’s other agents covertly and unlawfully videotape their victim and pay a crooked cop for a license to do so; then the Pope and the whole Catholic Church hierarchy lie about their priest’s and their victim’s actions and words and even bear false witness against him in legal proceedings around the world; then the whole Catholic Church hierarchy conspires to frame the guy and have him criminally prosecuted; and then the whole Catholic Church hierarchy get their parishioners to join in the hate, the lies and the framing; that would be a Scientology style black op.

I am still the victim of the Scientologists’ black ops, which comprise an aspect of the war they wage on different fronts and channels. Certain aspects are very visible, so are not really black ops, even though the visible parts are targets on programs that contain black ops department targets as well. The Scientologists’ legal operations in their war on me are largely visible, even if their black and invisible ops might determine judicial outcomes; e.g., judge-, witness-, jury-, attorney-tampering. Much of what I had to defend against, and spent my time defending against during the years you were part of the Scientologists’ war effort, was their lawfare machine. Despite being in the throes of litigation, of course, someone doesn’t have to lose the awareness that Scientologists comprise an intelligence cult and always have black ops targeting people, certainly their adversaries in the legal arena.

In any case, you were in the Scientology hierarchy during some of the years when I defended against the actions of the Scientologists and their collaborators in their war on me. This would be the 1980’s into the early 1990’s.

JP: Scientology sued Jerry for absconding with 22 banker boxes of personal documents and artifacts of L Ron Hubbard.

No. I did not abscond as you describe it. I did abscond, in that I blew, I deserted –from post, from serving Hubbard, from the Sea Org, and from Scientology. To abscond is to depart in a sudden and secret manner, which I did. I absconded because, if I had not absconded but let my seniors know I was planning to leave, the Scientologists would have locked me up, and would have Lisa McPhersoned me. Although I absconded, I did not, however, abscond with 22 banker boxes of Hubbard materials. I did not abscond with any Hubbard materials, certainly not the materials that became central to the Scientologists’ initial lawsuit against me.

I absconded on December 12, 1981 with my wife Jocelyn. I obtained the documents that were the subject of the first Scientology v. Armstrong suit in late spring, early summer 1982. I obtained them from Omar Garrison, legally and with his permission, for the purpose of sending them to my attorneys for safety and for my defense in the war I knew the Scientologists were bringing to me. The Scientologists filed their suit on August 2, 1982.

The Scientologists did not sue me for absconding with 22 banker boxes of Hubbard materials. They sued me for the actions I took while on post in Hubbard’s Personal PR Bureau as his Archivist/Researcher and as the “research assistant” identified in the contract between AOSH Pubs DK and Omar Garrison for Garrison to write Hubbard’s biography. I provided materials from Hubbard’s personal archive and from other sources to Garrison in 1980 and 1981 pursuant to this contract, which had been negotiated and written by Hubbard’s personal attorney Alan Wertheimer. The Scientologists sued me for “conversion,” claiming that while working with Hubbard’s materials inside the cult, I converted them to my own use. The Scientologists even claimed that I converted to my own use the “xerographic and photographic paper and chemicals,” which I had purchased and consumed making copies of biographical materials for Garrison.

The Scientologists, using CSC as the plaintiff, also falsely claimed in their complaint that the documents in Hubbard’s archive were CSC’s personal property, not that they were Hubbard’s. On that false basis, the Scientologists could claim that CSC never gave me permission to provide anything to Garrison. I was able to show by Garrison’s contract, by my communications back and forth with Hubbard, and by other evidence, that I had the necessary permissions to provide Garrison Hubbard’s materials. And I was able to show that I had Garrison’s permission to provide some of these materials to my attorneys.

The Scientologists know all this, and know what the judge at my trial in LA Superior Court in 1984 specifically ruled about the chain of possession of the subject documents and my permissions to do with them what I did.

Judge Breckenridge: The court has found the facts essentially as set forth in defendant’s trial brief, which as modified, is attached as an appendix to this memorandum. In addition the court finds that while working for L.R. Hubbard (hereinafter referred to as LRH), the defendant also had an informal employer-employee relationship with plaintiff Church, but had permission and authority from plaintiffs and LRH to provide Omar Garrison with every document or object that was made available to Mr. Garrison, and further, had permission from Omar Garrison to take and deliver to his attorneys the documents and materials which were subsequently delivered to them and thenceforth into the custody of the County Clerk.3

That judgment was affirmed on appeal in 1991.4 The Scientologists and their collaborators continue to lie about my lawful possession of Hubbard’s materials, and get others to lie for them. Marty Rathbun, who, under cult head David Miscavige, ran the Scientology v. Armstrong litigation, and who knows the judgment in the case very well, continued this lie in his 2013 book Memoirs of a Scientology Warrior.

MR: Armstrong became increasingly paranoid under pressure and finally got spooked enough to go to Flynn for help. Armstrong also brought with him several boxes of biography archives he had lifted from the church; documents that demonstrated to him that Hubbard’s personal biography, promoted by the church, was full of holes. Memoirs (p. 193)

To “lift” as Rathbun is using the term here means to steal, or pilfer. If there had been 22 bankers boxes, or even one banker’s box, they all would have required lifting as in raising them to a higher position, even if I had lifted them from a shelf above my head. Lord knows, I have lifted many bankers boxes, including bankers boxes of what could be called “biography archives.” Rathbun knows, bemoaningly perhaps, but without a doubt, that I did not lift Hubbard’s documents as the Scientologists claimed. Rathbun also knows that the LA Superior Court adjudged that I did not lift, as in steal or pilfer, the subject documents. Rathbun knowingly serves Miscavige’s purposes by forwarding this lie he knows is a lie. You are serving Miscavige’s purposes by forwarding this lie; probably, I would hope, without knowing it is a lie.

Lawrence Wright did the same thing in his 2011 article in The New Yorker, stating as fact that while in the cult working on the Hubbard biography I had copied the subject documents “without permission” and that the Miller, Atack and Corydon books “all rely on stolen materials,” referring to the materials that had come out through my litigation. In The New Yorker, Wright repeated the Scientologists’ relentless black PR line despite my providing him and the fact checking crew the facts well before publication. I requested that the magazine correct these false statements, which are defamation per se, and I showed by showers of facts and docs that Wright was wrong. I had an enormously wondrous exchange with The New Yorker’s general counsel, and came away with one heck of a story, but the magazine, despite knowing they were wrong, and with no evidence, just kept on proclaiming they were right. It had to be I’d run into an agenda item.

You don’t have to go the way of The New Yorker, however. It is weird when you consider that this is such an important point in people’s psyches that some with no clue write about it, and so do writers who do have a clue. I correct the record when it’s possible, but the Scientologists and their knowing and unknowing collaborators just keep the black PR coming.

JP: I’m not trying to retell the story of Jerry Armstrong here but ultimately, Scientology paid Jerry a settlement of $800.000 in exchange for his promise not to copy or discloses the content of the banker boxes he’d taken.

But you are retelling my story here, and again, I had not taken banker boxes. As far as I am concerned, the Scientologists paid me to dismiss my legal claims, my causes of action, against them before trial of these claims, then set in March 1987. My causes of action were for fraud, intentional infliction of emotional distress, libel, breach of contract, and tortious interference with contract. These arose from my 12 ½ years as a Scientologist victim of Hubbard and his cultists inside his Scientology cult, and from my 5 years as their wog victim of their fair game policy and actions after I left their cult. My dismissal of my claims was lawful for the Scientologists to settle with me.

The Scientologists and their collaborators claim in their attacks that what they paid me for was my agreement, on penalty of $50,000 per utterance, to maintain total silence about my experiences or knowledge relating to Scientology, Hubbard, orgs, groups, related entities, directors, officers, employees, volunteers, attorneys, etc., etc. Because Scientology is both a religion and a criminal conspiracy against rights, this is, clearly, to anyone with a clue, unlawful. It lawfully impermissibly violates the US Constitution, US laws, and international human rights charters. Therefore, these conditions cannot be what the Scientologists paid for.

The Scientologists could, probably lawfully, pay me whatever they wanted for any reason. The reason, however, could be unlawful, or unlawful in part. A litigation party could lawfully pay an opposing party to dismiss his legal claims; but that party could not, for example, pay another party, lawfully, to assassinate someone, a third party, as a condition of settlement. If such a contractual arrangement is lawful, the party who failed to execute the assassination contract could be punished for breach of contract. A very similar fact and legal situation exists in the Scientology v. Armstrong case.

JP: What the hell was in those boxes? It’s a fascinating, well documented cock up of what happened when author Omar Garrison and his research assistant Gerry Armstrong verified L Ron’s actual education and military record history among other subjects. In a nutshell, too much of the information they were able to factually verify of L Ron’s past was contemptuously contrary to the yarn L Ron spun for his devout adherents and any other ear that could hear. Gerry Armstrong went on to violate his agreement with Scientology hundreds of times and is still perused by Scientology’s attach dog legal machine.

Yes, I have violated the Scientologists’ condition that compels that I be completely silent about my now 45+ years of Scientology-related experiences and knowledge. I have violated that condition hundreds of thousands of times. I have even disclosed the content of the documents that were the subject of the Scientology v. Armstrong case, and I have copied documents that had once been in the case. But the key terms in the condition that I constantly violate are my experiences and knowledge, which cannot be but religious. And yes, I am still pursued and attacked by the Scientologists and their collaborators.

JP: I know something about this because I was present and informed about Jerry’s legal troubles with Scientology as they was happening. I recall being present when the conditions of the settlement agreement between Gerry Armstrong and Scientology (Which in effect included whatever was best for Author Services Inc, ASI) was negotiated.

As I wrote earlier, I was not present when the conditions of the Scientologists’ contract were negotiated. The existence and nature of negotiation is a factor in establishing a contract’s unconscionability. Mike Flynn presented the contract to me as a done deal. There was then no further negotiation regarding the conditions that I objected to and knew were impossible to comply with because Flynn stated that those conditions were “unenforceable,” “not worth the paper they’re printed on.” This was reasonable, and I am only more certain after all these years and throughout the Scientologists’ efforts to enforce their conditions that it is true.

JP: From 1983 until the settlement in 1986, I would receive on a daily basis, usually sometime between 6-8 pm, intelligence reports generated by staff of Special Project Operations (ASI), OSA and RTC concerning secret and illegal operations by Scientology against Jerry, his lawyer Michael Flynn, and other plaintiffs represented by Michael Flynn’s firm.

This is what I would like to interview you about.

In whatever communications I’ve had with you since you left the cult, this is the first time you’ve mentioned your involvement to that degree in the war on me. I’m surprised by that.

JP: The operations against Jerry’s lawyer included having knowledge of someone putting water in the gas tank of an airplane piloted by Michael Flynn with his son on board.

This became the subject of a case the Scientologists brought against Flynn in US District Court in LA. I believe it was dismissed as part of the December 1986 “global settlement.” I don’t recall Rathbun mentioning the airplane case in his Memoirs. Your knowledge could be helpful.

JP: There was instant access into the lives of people who were deemed enemy’s Scientology through well paid and placed private investigators. These professionals sold their services to their Scientology paymasters because they had the latest modern bugging technology that was confirmed US CIA grade technology. Scientology was able to buy the services of ex-police, ex-FBI and other agency. Phone records were a fruitful source of information. Through illegally obtaining phone records Scientology always seemed to be a step ahead of their perceived enemies. ASI lead attorney was Earle Cooley. A big part of his job as legal council was to made sure we rode a fine line to separate church principles from the illegal activities sanctioned by the same principles.

There were years of board room meeting at ASI to figure out how to get rid of Jerry Armstrong, L Ron junior, David Mayo and a few other people who had devoted their lives in servitude to L Ron and his grand ideas.

These ASI board room meetings are important, because the universal crime in Scientology is the conspiracy against rights. ASI, Hubbard’s personal for-profit company, was directing Scientology Church employees to get rid of people.

ASI board room meetings were, of course, after the “disbanding” of the Guardian’s Office. The Scientologists blamed all of their myriad public policy violations on the GO, in all sorts of legal filings, but most importantly in the submission to the IRS on which their 1993 tax exemption is based. You were doing at ASI exactly what the GO did in their war room meetings – figure out how to get rid of knowledgeable people who told the truth about Hubbard, Scientology and Scientologists.

JP: All of these devoted people turned out to be Suppressive Persons all along according to the instructions from L Ron via his publishing organization ASI. It was new management’s job to hunt them down and get them put in jail. Some may recall during the early to mid 1980’s L Ron got a bug up his ass and thought he had the power to have people criminally prosecuted for disobeying or being out of step with what he wanted. This is way past just having a stick up your ass, he really wanted this done and some people did get set up and went to jail. It was required protocol to hate and contribute to the destruction of men and women that I had never met or laid eyes on. We would be sitting in the board room at L Ron’s Author Services organization reading advice’s from L Ron calling for the heads of staff he felt offended him somehow. Listening to Miscavige and other staff figuring out ever clever ways to get rid of the people who were aggravating poor L Ron. As we sat there making up plans to attach the very same people who were at L Ron’s side doing everything in their power to do his will. L Ron never wavered when it came to annihilating the oldest and closest devote adherents he had. There is no retirement in the business of Scientology. Ron taught his prodigy to quickly and quietly get rid of the most loyal staff members without remorse.

There were banker boxes full of “advises” from L Ron spewing hate filled vitriol about Jerry. The information that Jerry provided to Russell Miller and Jon Attack about L Ron’s actual history did in fact exposed his underbelly and pulled back the curtains on his imaginary life he expected others to believe.

Now is a great time to make those bankers boxes known about, in as much detail as you can recall. There’s another volume: Ron the Vitriologist.

JP: During the negotiations to settle with Jerry Armstrong the settlement was intentionally construed to make it too easy for anyone to claim Jerry had violated his agreement with Scientology. Those who were present knew this settlement, that still plagues Jerry today was not done in good faith. The actual intent of the settlement was to cause Jerry to be incarcerated for violation of his settlement agreement and that is exactly what has happened. The other factor is this; Jerry didn’t want to take any of Scientology’s money and he didn’t want to settle. He was in effect forced to settle by his own lawyer Michael Flynn. Michael Flynn and his whole family had been hounded by Scientology hired thugs and they were tired of it. Flynn was also the attorney of record for other ex-Scientologist in a civil class action lawsuit….you get the idea.

That’s not really true. I was willing to settle with the Scientologists. I have no problem with taking their money. The Scientologists did not know what I would be receiving to dismiss my claims. They paid a lump sum to Flynn and he distributed it to his clients as agreed between him and us. I had no compulsion to not settle and instead to force a trial of my claims. I had already exposed Hubbard and the Scientologists. The amount that the Scientologists paid me to avoid a trial was reasonable, and I have never complained about that sum. I was not, however, willing to never discuss my experiences or knowledge, nor to be the Scientologists’ punching bag with no right to defend myself. I knew the Scientologists’ contract was unconscionably one-sided, and I considered it another act of fair game, not a sincere effort to end the conflict between us. I would urge you to listen to my discussion of the settlement in Berlin in 2011:

JP: We had them right where we wanted. Each person received a settlement but Jerry was the only hold out. We even knew about the deteriorating relationship between Jerry Armstrong and lawyer Michael Flynn because we were the ones causing the confusion. In the end Jerry was forced to settle or be attached by his own attorney who wanted out and had been working on contingency anyway. There are standard legal agreements a plaintiff makes with a lawyer who takes on a case on contingency. The rule and agreement that comes into play is the plaintiff will agree to settle the case if there a reasonable offer on the table. Jerry was obligated to accept the settlement.

No, this isn’t the way it was. You Scientologists didn’t really have me where you wanted me. You didn’t know which way I’d go. I was not bound by any rule of contingency fee agreements that obligated me to settle, and nothing relating to this concept came up in my discussions with Mike Flynn or anyone else at the time of the settlement. As I said, the reasonable monetary offer to settle the case I had known and accepted. The impossible, unconscionable, unconstitutional and unlawful, but severable, conditions that the Scientologists have been judicially enforcing against me I had not known about. There was no deteriorating relationship between Flynn and me that I was even slightly aware of. What you were doing, and knew others were doing, to cause what you believe was a deteriorating relationship between Flynn and me is very relevant in a number of contexts. The remaining Scientologists and their collaborators still do not have me right where they want. They all need to stop wanting to have me where I won’t be.

JP: Someone can say that better than me but you get the idea, Jerry was forced to settle, then he was set up to violate the settlement whereby Scientology would recover its money times three and if possible get him arrested and put in jail.

I was under mind-altering duress to sign the Scientologists’ settlement agreement, but not from the contingency nature of Flynn’s and my attorney-client relationship. Again, the video I think best explains the situation and the pressures at the time of the settlement.

JP: After years of acting like I hated people I’d never met or seen with my eyes like Jerry Armstrong took some getting use to. Getting Jerry had been en grained in my mind. Even after being out of the cult for some years. I remember the first time I talked with Jerry years after I had left the cult. On a physical level I felt uncomfortable being around him or even engaging in personal or meaningful conversation. On a certain level I was afraid of Jerry and this made no sense. None of that changed the facts of how all of this made me feel emotionally. In L Ron’s alternative reality, it was considered a flaw to openly show or express emotion or empathy. We were all just ever replaceable characters in L Ron’s movie. Suffice to say I didn’t foster or encourage a speaking relationship with Jerry because I didn’t want to. The problem is this is how Scientology technology is designed to protect itself in the minds of its own.

Long before I testified in a court of law as an expert witness, Jerry had already been there doing that, the same as I would do later. The real truth is when I met Jerry I had not entirely overcome the misconceptions and false information I’d learned about him through the years. I was dismissive of Jerry and didn’t fully appreciate, let alone realize the personal sacrifice and contribution he made when he exposed L Ron for being the lying ass clown he was.

That was the 1980’s. Now I’m dealing with what the Scientologists have done and are doing in retaliation for what I did then. This is where you can help.

JP: It was only after reading the Russell Miller book with fresh eyes that I finally better understanding and more fully appreciated the work Jerry did.

The work I’m doing now is what is important. The war did not end when Hubbard was exposed as a liar, and it is in the war, in which you participated, that your testimony of times, places, forms and events is wanted.

JP: Since I’ve read the books again with fresh eyes so much has changed. I know I was Jerry when I woke up from the spell and stopped lying for and protecting Scientology. That meant it was my turn to be persecuted by juvenile intelligence tactics, endlessly financed on behalf of dead L Ron. These days both Marty Rathbun and Mike Rinder are Jerry too! No one owes or is obligated to me for anything and ultimately it may not matter what I think but I will say this. I don’t monitor Scientology activities anymore like I use to. That being said, It sure does make me smile when someone sends me something about Mike Rinder speaking out. He’s even been known to refer to Scientology as a cult. This is the guy who was the public face of Scientology for years! My heart goes out to him and his new family. These days Mike doesn’t mince words when tells people about Scientology, what a turnaround bless him. Marty Rathbun is probably the most knowledgeable person in existence when it comes to how Scientology plays ball in a law suit. From what I can tell he and his wife are progressing excellently with their lawsuit against Scientology, you have my blessing for that.

Rathbun and Rinder still support the Miscavige Scientologists in their war on me, and people connected to me. Rathbun and Rinder need to shift their misplaced allegiance from that most unjust cause to their victims.

Please correct the fact errors about me I’ve pointed out in your article. And I look forward to debriefing you about your Scientology v. Armstrong war stories, experiences and knowledge.

Thank you.


Appellant’s Opening Brief (January 19, 1993)


Civ. No. B 069450
(Super. Ct. No. BC 052395)


On Appeal From

Superior Court Of The State Of California
County of Los Angeles

The Honorable Ronald M. Sohigian


Ford Greene
California State Bar No. 107601
711 Sir Francis Drake Boulevard
San Anselmo, California 94960-1949
Telephone: (415) 258-0360

P.O. Box 511
Pacific Palisades, California 90272
(213) 459-4745

Attorneys for Appellant GERALD ARMSTRONG



On February 4; 1992, Scientology filed its verified complaint for damages and for preliminary and permanent injunction against defendant Gerald Armstrong in Marin County Superior Court Action No. 152229. On March 30, 1992 the Marin court granted Armstrong’s motion to transfer to the Los Angeles County Superior Court where it became Action No. BC 052395. During the pendency of Scientology’s motion for injunctive relief, and in order to maintain the status quo, but specifically stating there was no adjudication on the merits, the Marin Court granted a temporary restraining order (16) 1/ which was ultimately dissolved in Los Angeles.
On May 7, 1992, Scientology filed its Amended Memorandum of

1 All citations designated (___) are to the particular sequential page number of the Appendix Filed In Lieu Of Clerk’s Transcript pursuant to California Rule of Court 5.1.



Points and Authorities in Support of Plaintiff’s Motion for Preliminary Injunction for Breach of Contract (1-29), and Armstrong filed his Opposition to Motion for Preliminary Injunction. (30-50) Scientology replied on May 20, 1992. (51-63) The matter was heard on May 26 and 27, 1992 by the Honorable Ronald M. Sohigian (RT 5/26/92 and 1594-1713) who issued a preliminary injunction by his minute order dated May 28, 1992. (1714-17) Notice of ruling was given on June 5, 1992 in conjunction with the posting of a $70,000.00 bond.

Armstrong’s Notice of Appeal was timely filed on July 30, 1992. (1728-30)


Since this matter involves the granting of an injunction, it is the proper subject of an appeal. Code of Civil Procedure section 904.1 (f).


A. Gerald Armstrong, The Scientologist

In consequence of being a member of the Scientology Organization for 12 years, Gerald Armstrong gained first-hand knowledge regarding both the nature of the organization and the methods of its day-to-day operations. Although Armstrong ultimately learned, that L. Ron Hubbard (“LRH”) was “virtually a pathological liar when it [came] to his history, background, and achievements” (474-75, 485-89, 1004, 1008-14), at the outset of his involvement it was Hubbard’s lies which induced his affiliation. (1004-08, 1067)

Armstrong learned that after inducing the affiliation of its members by various deceptions, Scientology continually “violat[ed] and abus[ed] its own members’ civil rights, . . . with its “Fair Game” doctrine [and] harass[ed] and abuse[ed] those persons not in the Church whom it perceive[d] as enemies.” (474) The “Fair Game Policy,” a part of Scientology’s system of discipline and punishment, states:



“Enemy – SP (Suppressive Person) Order. Fair Game. May be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. May be tricked, sued or lied to or destroyed.”


Scientology also abused its members’ civil rights through breaching its promises that the personal information it extracted from adherents through “auditing” 2/ would be kept confidential. Instead, it used such information for the purposes of domination, extortion and blackmail. (734-74, 1039-41) Auditing was also employed to eliminate the members’ ability to critically reason, (1038, 1081), despite Scientology’s public claim that its purpose was to free individuals. (1086)

Armstrong possesses first-hand information regarding the visible structure of Scientology, and how the leadership ran Scientology through internal organizations, such as the Guardian’s Office, the Sea Organization and the Commodore’s Messenger Organization, which managed, operated and controlled all of Scientology regardless of any particular corporate designation. (475, 997, 1023-30, 1045-46). He knew that LRH’s representation to the general public and the Scientology membership that “the fees you pay for service do not go to me” was false and that LRH lived in splendor while the organization staff lived like slaves. (1032-34)

Armstrong participated in and drilled hundreds of people in

2 During the process of “auditing” in Scientology, a person being “audited,” a “penitent,” communicates to the clergyman, counselor, or therapist, the “auditor,” his innermost thoughts and relates incidents from his life which are emotionally charged, embarrassing or for which he could be blackmailed. The auditor writes down what the penitent says in “auditing reports.” The auditor demands and records details such as time and place when an incident occurred, who was present, who knew about the incident, their relationship to the penitent and their address or general location. These “auditing reports” form, along with the auditor’s notes and instructions made after the auditing sessions, the penitent’s auditing files. (1081)



institutionalized schemes of practiced deception called “shore stories” or “acceptable truths,” which LRH claimed were required to combat the “enemy.” (1051, 1016-19, 787-88)

Armstrong was assigned to the Intelligence Bureau of the Guardian’s Office 3/ headed by LRH and his wife and then posted as LRH’s communications aide. (996) During this time he coded and decoded Guardian’s Office telexes, and maintained LRH’s operations files including those which ordered infiltration of the federal, state and local government offices, and the theft of documents. Armstrong also handled LRH’s telexes and dispatches ordering corporate manipulations which showed an absence of corporate integrity among the Scientology organizations.(1045-46)

LRH ordered Armstrong and his wife into the Rehabilitation Project Force (“RPF”), which was “a virtual prison Hubbard had created for any Sea Org members whom he considered to be in violation of or ‘counter-intention’ (“CI”) to his orders or policies.” (997; 738; 1048-49) The purpose of the RPF was to control members, who were physically held and not free to leave, break their will and obtain free labor. (740, 1050) Armstrong was imprisoned within the RPF for 17 months on one occasion and 8 months on a second. (739, 997, 999, 1048)

Armstrong personally participated in the massive destruction of evidence ordered in anticipation of a raid by the F.B.I. during which he came across LRH’s life archive. (480-81, 485-86, 1000-01) Throughout 1980 and 1981, Armstrong assembled an
3 “The Guardian’s Office is charged with the protection of Scientology. The Guardians handle intelligence matters including covert operations to acquire Government documents critical of Scientology, internal security within Scientology, and covert operations to discredit and remove from positions of power all persons whom Scientology considers to be its enemies.” United States v. Heldt (1981) 668 F.2d 1238, 1247, cert. denied (1982) 102 S.Ct. 1971. The Guardian’s Office executed tremendous control throughout all of Scientology, and until 1981, was the most powerful of LRH’s two main control lines. (1023-28)



archive of 500,000 pages of documentation of LRH’s life, writings and accomplishments. (1003) In October 1980, LRH contracted with an independent author, Omar V. Garrison, to write his
biography. (1004) Armstrong became Garrison’s “research assistant.” (1004; 483-85)

During his biographical research, Armstrong discovered that LRH and Scientology had continuously lied about LRH’s past, credentials and his accomplishments. (486, 1008-14) As the wide gap between LRH’s claims about himself and the reality evidenced by the documentation Armstrong had assembled became manifest, he attempted to convince Scientology executives to change the biographical materials being published and disseminated about LRH so that they would be truthful. (1004; 486-87)

In response to Armstrong’s requests that Scientology tell the truth about Hubbard, a leader ordered that Armstrong be “security checked. (487) Sec checking is a brutally accusative interrogation in which the E-Meter, the electrometer used in Scientology auditing, is employed as a lie detector and tool of intimidation. Upon learning that his sec checking had been ordered, Armstrong and Jocelyn, his wife, left Scientology. (1015)

Following Armstrong’s departure, Scientology sued him, and hired private investigators who assaulted him, ran into him bodily with a car, attempted to involve him in a freeway accident, and followed and harassed him day and night for over one month. Scientology made four attempts to bring false criminal charges against him, destroyed his marriage, used his best friend to set him up in an intelligence operation, and had its members, lawyers and private investigators make false statements against him. (1053, 492-93)

B. Scientology Sues Armstrong The First Time And Loses

On August 2, 1982, Scientology sued Armstrong in L.A.S.C. No C420153 (“Armstrong I“) for conversion of certain papers which he had archived as part of the Hubbard biography project. After a



lengthy trial, Judge Paul G. Breckenridge, Jr., filed his Memorandum of Intended Decision in Armstrong’s favor on June 22f 1984. (467) Rejecting Scientology’s effort to silence Armstrong and his counsel, (see 1202-1226), he stated:

Defendant and his counsel are free to speak and communicate upon any of Defendant Armstrong’s recollections of his life as a Scientologist or the contents of any exhibit received in evidence or marked for identification and not specifically ordered sealed. . . . defendant and his counsel may discuss the contents of any documents under seal or of any matters as to which this court has found to be privileged as between the parties hereto, with any duly constituted Governmental Law Enforcement Agency or submit any exhibits or declarations thereto concerning such documents or materials, without violating any order of this court.

(469) Judge Breckenridge found the facts presented by Armstrong to be true and incorporated Armstrong’s trial brief as an appendix to its decision. (470) He characterized Scientology as malevolent, in part because the organization “or its minions is fully capable of intimidation [of witnesses, including Armstrong] or other physical or psychological abuse if it suits their ends” (474), and provided the following factual findings:

In 1970 a police agency of the French Government conducted an investigation into Scientology and concluded “this sect, under the pretext of ‘freeing humans’ is nothing in reality but a vast enterprise to extract a maximum amount of money from its adepts by (use of) pseudo-scientific theories, by (use of) ‘auditions’ and ‘stage settings’ (lit. to create a theatrical scene’) pushed to extremes (a machine to detect lies, its own particular phraseology . . ), to estrange adepts from their families and to exercise a kind of blackmail against persons who do not wish to continue with this sect.” [footnote omitted] From the evidence presented to this court in 1984, at the very least, similar conclusions can be drawn.

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 Church whom it perceives as enemies. The organization is clearly schizophrenic and paranoid, and this bizarre combination seems to be a reflection of its founder LRH [L.


Ron Hubbard]. 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.

(Emphasis added.) (474)

In contrast to his findings regarding Scientology, Judge Breckenridge found Armstrong and his witnesses to be credible and sympathetic. He wrote:

As indicated by its factual findings, the court finds the testimony of Gerald and Jocelyn Armstrong, Laurel Sullivan, Nancy Dincalcis, Edward Walters, Omar Garrison, Kima Douglas, and Homer Schomer to be credible, extremely persuasive and the defense of privilege or justification established and corroborated by this evidence . . . In all critical and important matters, their testimony was precise, accurate, and rang true. The picture painted by these former dedicated Scientologists, all of whom were intimately involved [with the highest echelons of power in] the Scientology Organization, is on one hand pathetic, and on the other, outrageous. Each of these persons literally gave years of his or her respective life in support of a man, LRH [L. Ron. Hubbard], and his ideas. Each has manifested a waste and loss or frustration which is incapable of description.

(Emphasis added.) (473)

C. Scientology’s Attempt To Frame Michael Flynn 4/

Within four months of Judge Breckenridge’s decision, Scientology engaged in a massive “black PR” campaign against Michael Flynn which included the following operation:

The recent efforts of Hubbard and his Organization include procurement through the payment of $25,000 to an individual currently under indictment for perjury and fraud, of an affidavit claiming that I assisted in the forgery of a two million dollar check belonging to L. Ron Hubbard. The affidavit was procured by one Eugene Ingram who has been removed from the Los Angeles

4 This section is based upon the Declarations of Michael J. Flynn, Armstrong’s attorney. The Court should note that said declarations, however, were excluded from evidence. The trial court was incorrect however, because said declaration were based upon the personal knowledge of Flynn.



Police Department for aiding narcotics dealers, pimping, and running a house of prostitution. Mr. Ingram procured the affidavit from a citizen of the United Arab Emirates after publicizing a $100,000 reward in full page advertisements in the Boston Globe, the New York Times, and other newspapers.

(1183-84) The foregoing facts were found to be accurate in the reported decision, United States v. Kattar (5th Cir. 1988) 840 F.2d 118, 119-22.

D. Scientology’s Attempt To Frame Armstrong

In 1984, after the Breckenridge decision, Scientology also attempted to set up and frame Armstrong, to “dead agent” him. As stated by Scientology in the Miller, Aznaran, and Xanthos litigation (discussed infra.)

Gerald Armstrong has been an admitted agent provocateur of the U.S. Federal Government who planned to plant forged documents in [Scientology’s] files which would then be “found” by Federal officials in subsequent investigation as evidence of criminal activity.

(1546-50; see also (1320). He had been

“plotting against … Scientology … and seeking out staff members who would be willing to assist him in overthrowing [Scientology] leadership. [Scientology] obtained information about Armstrong’s plans and, through a police-sanctioned investigation, provided Armstrong with the “defectors” he sought. On November 30, 1984, Armstrong met with one Michael Rinder, an individual whom Armstrong thought to be one of his “agents” (but who in reality was loyal to [Scientology]). In the conversation, recorded with written permission from law enforcement, Armstrong stated the following in response to questions by Mr. Rinder as to whether they had to have actual evidence of wrongdoing to make allegations in Court against [Scientology’s] leadership:

Armstrong: They can allege it. They can allege it. They don’t even have — they can allege it.

RINDER: So they don’t even have to — like — they don’t have to have the documents sitting in front of them and then–

Armstrong: Fucking say the organization destroys documents. . . . Where are the — we don’t have to prove a goddamn thing. We don’t have to prove shit; we just have to allege it.



(Ex. E, Declaration of Lynn R. Farney, ¶ 6.) With such a criminal attitude, Armstrong fits perfectly into Yanny’s game plan for the Aznaran case.”


The “written permission from law enforcement” was fraudulent and made without authority. The bogus document was dated November 7, 1984 on the letterhead of Eugene Ingram. (1572)

By public announcement, Los Angeles Chief of Police, Daryl F. Gates, repudiated the “written permission.” In part, Chief Gates stated:

I have directed an official letter to Ingram informing him that the letter signed by Officer Phillip Rodriguez dated November 7, 1984, and all other letters of purported authorizations directed to him, signed by any member of the Los Angeles Police Department, are invalid and unauthorized.


Scientology’s allegations against Armstrong were thoroughly investigated by the Los Angeles County District Attorney’s Office and completely and soundly rejected. (1576-87)

E. The Settlement

In the Armstrong I litigation, on both the complaint and cross-complaint, Armstrong was represented by Boston attorney Michael J. Flynn, who also was Armstrong’s employer. (665) In early December 1986, an agreement was reached in Los Angeles by the Scientology Organization and Flynn to settle most of the cases in which Flynn was involved, either as counsel, or as a party. On December 5, 1986, Armstrong, along with nearly a score of other litigants adverse to Scientology – all of whom were represented by Flynn – was flown to Los Angeles to participate in a “global settlement.” (667) When Armstrong arrived in Los Angeles from Boston, he knew that settlement negotiations had been going on for months. (762) Upon Armstrong’s arrival, he was shown a copy of a document entitled “Mutual Release of All Claims and Settlement Agreement” for the first time, as well as some other documents that he was expected to sign.

When Armstrong read the settlement agreement, he was shocked



and heartsick. The agreement betrayed everything that Armstrong had stood for in his battle opposing Scientology. (760) He told Flynn that the condition, set forth in settlement agreement ¶ 7-D, of “strict confidentiality and silence with respect to his experiences with the [Scientology organization]” was outrageous and not capable of compliance because it involved over 17 years of his life. Armstrong told Flynn that ¶ 7-D would require him to pay $50,000 if he told a doctor or a psychologist about his experiences over those 17 years, or if he put on a job resume the positions he had held while in Scientology. He told Flynn that the requirements of non-amenability to service of process in ¶ 7-H and non-cooperation with persons or organizations adverse to the organization in ¶ ¶ 7-G and 10 were obstructive of justice. Armstrong told Flynn that agreeing in ¶ 4-B to allow Scientology’s appeal of Judge Breckenridge’s decision in Armstrong I to continue without opposition was unfair to the courts and all the people who had been helped by the decision. Armstrong said to Flynn the affidavit that Scientology demanded he sign along with the settlement agreement was false. (668, 759)

Right after Armstrong first saw the document, he was told there were a number of other people with claims against Scientology who had already signed and others were being flown in to sign. (762) Flynn told Armstrong that he, and all the other lawyers, wanted to get out of the litigation because it had ruined his marriage and his wife’s health. Flynn told Armstrong that all the other witnesses upon whom later he would have to depend wanted to settle, too.

In Flynn’s presence, Eddie Walters, another litigant adverse to Scientology, yelled at Armstrong. Walters said everybody wanted out of the litigation, that Armstrong’s objections would kill the deal for all of the them, and that Armstrong’s objections didn’t matter because the settlement was bigger than he was. (762-63) Flynn did not stick up for Armstrong. (764)



Flynn told Armstrong if he did not sign all he had to look forward to would be more years of threats, harassment and misery from Scientology, and everybody else would be very upset. Flynn advised Armstrong that the conditions of the settlement which he found offensive “were not worth the paper they were printed on” and that Scientology’s lawyers were aware of Flynn’s legal opinion and, nonetheless, wanted such language included. (759) Flynn advised Armstrong that in the event that there was further litigation against Armstrong by Scientology, Flynn would still be there to defend him. (768) Armstrong felt “a great deal” of pressure to sign the agreement, and capitulated. (761, 765-66, 772; 670-71)

It was Armstrong’s understanding and intent at the time of the settlement that he would honor the silence and confidentiality provisions of the settlement agreement, and that Scientology would do likewise. (672)

On December 11, 1986, Flynn and Scientology attorneys John G. Peterson, Michael Lee Hertzberg and Lawrence E. Heller appeared, ex parte, before Judge Breckenridge, announced that they had settled Armstrong’s Cross-Complaint in Armstrong I (458), and submitted a number of documents for filing. (1235-36, 1238, 1240-41, 1243-45, 1247-49, 1251.) Despite its promises, Scientology never did file the settlement agreement. (1258)

When Judge Breckenridge inquired whether the agreement impacted the appeal of his decision, the attorneys said that the agreement did not (458), despite Paragraphs 4-A and 4-B. (75-76) None of the attorneys advised Judge Breckenridge of their side stipulation that any retrial of Armstrong I ordered by the Court of Appeal would limit damages claimed by Scientology to $25,001, (1253) 5/ and they failed to advise him there was another side

5 Said stipulation, signed by Michael Flynn on Armstrong’s behalf and by John Peterson and Michael Hertzberg for Scientology and Mary Sue Hubbard, states: “The Church of Scientology of California, Mary Sue Hubbard, and Gerald



agreement between Flynn and Scientology attorneys Cooley and Heller whereby they agreed to indemnify Flynn if the Court of Appeal reversed Armstrong I and they retried the case and won. (1255-56)

Moreover, prior to and at the time of the settlement Armstrong was not aware of the side agreements between his lawyers and the lawyers for the organization that considered Gerald Armstrong as their enemy! (712-13, 715; 771-72)

On December 18, 1986, the Court of Appeal dismissed appeal No. B005912 as premature because Armstrong’s cross-complaint remained to be tried. (1260-73) 6/

On January 30, 1987, Scientology filed an Unopposed Motion to Withdraw Memorandum of Intended Decision in Armstrong I. (1279-83) which Judge Breckenridge denied. (1285) Scientology then filed its second appeal in Armstrong I. (1287) On July 29, 1991, the Court of Appeal affirmed Judge Breckenridge’s decision. Church of Scientology of California v. Armstrong (1991) 232 Cal.App.3d 1060, 283 Cal.Rptr. 917.

F. Scientology’s Post Settlement Breaches

1. The Corydon “Dead Agent” Pack

In 1987, less than one year after the agreement was signed,

Armstrong, by and through their undersigned counsel, hereby stipulate that in any retrial ordered by any appellate court in Church of Scientology of California v. Gerald Armstrong, LASC No. 420153, the total damages awarded to the Plaintiff Church of Scientology of California and Plaintiff in Intervention Mary Sue Hubbard, combined for any and all causes of action, shall not exceed twenty five thousand and one dollars ($25,001.00).”

6 The Court of Appeal would not have been advised of the resolution of the underlying Cross-Complaint in Armstrong I – on the existence of which it based its order of dismissal of the appeal – because the fate of said appeal was the subject of Paragraphs 4-A and 4-B of the secret agreement.



Scientology distributed a “dead agent” 7/ pack which included an attack on Armstrong. It stated:

“Corydon has used a description of the RPF provided by Gerry Armstrong, among others. Armstrong’s description in this book, however, is completely contrary to his own previous sworn affidavit about the RPF. (Gerry Armstrong’s description of the RPF in Corydon’s book can also be viewed in light of Armstrong’s numerous false claims and lies on other subject matters.)”

(1504) (Emphasis added.)

2. Scientology’s Declarations In The Miller Litigation

In October, 1987, Scientology representative Kenneth Long executed five affidavits in Church of Scientology of California v. Miller, High Court of Justice, Chancery Division, No. 1987 C. No. 6140, wherein Long solely discussed his characterizations of Armstrong’s activities that had been at issue in the Armstrong I litigation, and thus included within the scope of the settlement agreement. (See Appendix pp. 1506-23; 1525-44; 1546-50, 1555-62, 1564-70)

Long’s third affidavit falsely charged that:

Gerald Armstrong has been an admitted agent provocateur of the U.S. Federal Government who planned to plant forged documents in [Scientology’s] files which would then be “found” by Federal officials in subsequent investigation as evidence of criminal activity. (1549)

In another affidavit filed in the Miller case on October 5, 1987, Sheila M. Chaleff also falsely stated:

Mr. Armstrong is known to me to be a US government informant who has admitted on video tape that he intended to plant

7 “A ‘dead agent’ is a concept created by Hubbard in which an agent who is supposedly spreading stories about you, a lie, an untruth in his story is found. And that is documented. [¶] And then that documented fact is circulated to all of the people to whom the agent has communicated, and then he will become essentially dead, he will be killed by those people who have earlier trusted him. So you’ve destroyed his credibility and as an agent he is dead. [¶] And this pack of materials was a dead agent pack put out to dead agent Bent Corydon. Bent Corydon had written a book about Hubbard, and this is a pack of materials to discredit Bent Corydon.” (791)



forged documents within the Church of Scientology and then using the contents to get the Church raided where these forged documents would be found and used against the Church.


3. Heller’s Declaration And Argument In The Corydon Litigation

On or about November 1, 1989, in the case entitled Corydon v. Church of Scientology International, Inc., et al., LASC No. C694401, Scientology attorney Lawrence E. Heller filed a Notice of Motion and Motion of Defendant Author Services, Inc. to Delay or Prevent the Taking of Certain Third Party Depositions by Plaintiff. (1294-1305) In his memorandum, Heller discussed the “block settlement” of which the Armstrong agreement was a part:

One of the key ingredients to completing these settlements, insisted upon by all parties involved, was strict confidentiality respecting: (1) the Scientology … staff member’s experiences within … Scientology; (2) any knowledge possessed by the Scientology entities concerning those staff members …; and (3) the terms and conditions of the settlements themselves. Peace has reigned since the time the interested parties entered into the settlements, all parties having exercised good faith in carrying out the terms of the settlement, including the obligations of confidentiality. [Original emphasis.]

(1297) In his sworn declaration, attorney Heller testified:

I was personally involved in the settlements which are referred to in these moving papers which transpired some two and one-half years ago. . . . a “universal settlement” was ultimately entered into between the numerous parties. The universal settlement provided for non-disclosure of all facts underlying the litigation as well as non-disclosure of the terms of the settlements themselves. The non-disclosure obligations were a key part of the settlement agreements insisted upon by all parties involved. [Original emphasis.]


4. Scientology’s Complaint Against The IRS

On August 12, 1991, Scientology filed a complaint styled Church of Scientology International v. Xanthos, et al., in United States District Court, Central District of California, No. 91-4301-SVW(Tx). (1307-47) Therein, Scientology stated:


The infiltration of [Scientology] was planned as an undercover operation by the LA CID along with former [Scientology] member Gerald Armstrong, who planned to seed [Scientology] files with forged documents which the IRS could then seize in a raid. The CID actually planned to assist Armstrong in taking over the [Scientology] hierarchy which would then turn over all [Scientology] documents to the IRS for their investigation.


5. The Aznaran Litigation

On or about August 26, 1991, Scientology filed its Supplemental Memorandum in Support of Defendants’ Motion to Dismiss Complaint with Prejudice in Aznaran v. Church of Scientology of California, et al. United States District Court, Central District of California, No. CV-88-1786-JMI(Ex). (1349¬59) Therein, a Scientology attorney stated that in 1984 Armstrong was

“plotting against … Scientology … and seeking out staff members who would be willing to assist him in overthrowing [Scientology] leadership. [Scientology] obtained information about Armstrong’s plans and, through a police-sanctioned investigation, provided Armstrong with the “defectors” he sought. On November 30, 1984, Armstrong met with one Michael Rinder, an individual whom Armstrong thought to be one of his “agents” (but who in reality was loyal to [Scientology]). In the conversation, recorded with written permission from law enforcement, Armstrong stated the following in response to questions by Mr. Rinder as to whether they had to have actual evidence of wrongdoing to make allegations in Court against [Scientology’s] leadership
• • •

(Ex. E, Declaration of Lynn R. Farney, ¶ 6.) With such a criminal attitude, Armstrong fits perfectly into Yanny’s game plan for the Aznaran case.”

Armstrong was cleared by the Los Angeles District Attorney after a thorough – and Scientology generated – investigation. (1576-87)

G. Armstrong’s Post Settlement Breaches

Scientology’s position at the hearing below was that Armstrong violated paragraphs 7-G and 7-H of the settlement



agreement. (81-82) The violations were predicated upon the facts that Armstrong had worked for two days in the office of Joseph A. Yanny and had executed two declarations to be filed in the Aznaran case (122-23; 128; 136-38), had later executed a declaration on Yanny’s behalf that was filed in Religious Technology Center v. Yanny, LASC No. BC 033035, (124-34), and had worked as a paralegal for Ford Greene in the Aznaran case (143
45; 159-64; 169) in which Armstrong filed another declaration on the Aznarans’ behalf. (147-57; RT 5/27/92 at 47)



  1. This document in PDF format.

Deposition of Vicki J. Aznaran (May 9, 1989)







NO. CV 88-1786-WDK



On the 9th day of May 1989, at 10:00 a.m. the oral deposition of the above-named witness was taken at the instance of the defendants before Roger W. Miller, Certified Shorthand Reporter in and for the State of Texas, at the offices of Stanley, Harris, Rice, 3100 McKinnon, Suite 1000, in the City of Dallas, County of Dallas, State of Texas, pursuant the agreement hereinafter set forth.



A.      What money was spent or how much money was spent, which I believe was 250,000.

Q.      Anything else you remember telling the FBI about that incident?

A.      I told them that it was Dick Story and Dick Bass were largely the players involved.

Q.      Any other details you recall telling the FBI about that?

A.      No, not offhand, I don’t recall anything else.

Q.      Are there any other instances involving judges that you discussed with the FBI?

A.      They wanted to know about Scientology executives going to see Marianna Pfaelzer one night.

Q.      Anything else? That’s what you already talked about with Mr. Cooley, is it not?

A.      Yeah. I think we went into that.

Q.      Any other judges?

A.      Yeah. Breckenridge and the Judge on the — the original Judge on the Wollersheim case. I don’t know if “original” is the right word, but he was a judge on the case during, I believe, pretrial.

Q.      What did you tell the FBI about Judge Breckenridge?

A.      I told him about destroying documents that



Judge Breckenridge had ordered produced.

Q. What did you tell him about destroying those documents?

A. What did I tell him? I don’t remember specifically. That there were documents that he ordered his folders produced, and myself and some others went through those folders and took out and destroyed documents out of them that we did not want turned over.

Q. When you say he wanted his folders produced, who is that, judge Breckenridge?

A. Yeah. He ordered them turned over to him.

Q. His own folders?

A. Armstrong’s, Jerry Armstrong’s.

Q. And what did you tell the FBI about the first judge on the Wollersheim case?

A. Well, supposedly he had a son who was homosexual, and there was some — some operation withthe son’s boyfriend, which was brought up to the Judge in order to try to get rid of that Judge, if —

Q. Do you recall any more —

A. I believe that’s what I told him, the drift of it, anyway.

Q. Do you recall telling him anything else about that incident?

A. Not specifically, no.



Q. Were you involved in that incident in any way?

A. Peripherally. No, not really. I was just there part of the time.

Q. It was not done at your instigation?

A. No.

Q. You did not participate in anything involving the Judge Pfaelzer incident directly?

A. Staff members — well, no, not really.

Q. You personally, I’m not —

A. Yeah. No, not really.

Q. Now, your knowledge of the facts that you related to the FBI concerning Judge Breckenridge is firsthand, from what I understand you are saying?

A. The destruction of the documents?

Q. Yes.

A. Yes.

Q. You participated in it?

A. Yes.

Q. And you told that to the FBI?

A. Yes:  .

Q. And what is the source of your information concerning the first Judge on the Wollersheim case?

A. I believe David Miscavige.

Q. He told you about it?








This is to certify that I, Roger W. Miller, Certified Shorthand Reporter in and for the State of Texas, reported in shorthand the proceedings conducted at the time and place set forth in the caption hereof and that the above and foregoing pages contain a full, true, and correct transcript of said proceedings.

Given under my hand and seal of office on this the 9th day of May, 1989.

[signed Roger W. Miller]
Roger W. Miller, Certified
Shorthand Reporter No. 328
in and for the State of Texas
My commission expires December 31, 1989.


Declaration of Vicki J. Aznaran (August 9, 1988)

I, Vicki J. Aznaran, make the following declarations on personal knowledge except where the context indicates knowledge based upon information and belief.1

My husband Richard Aznaran and I are plaintiffs in the instant action wherein defendants (hereinafter referred to collectively as “Scientology”) have moved to strike our entire complaint and to prevent our attorneys from representing us.

2. As set forth in more detail below, my husband and I were involved with Scientology for approximately 15 years. For much of that time we were members of an organization known as the Sea Organization. This organization is an elite organization within Scientology. The Sea Organization has considerable influence and control over Scientology organizations. Generally, Sea Organization members hold the management posts within Scientology.

3. In 1978, after approximately four years as staff members, my husband and I joined the Sea Organization. From 1978 to early 1987, my husband and I worked most of our waking hours, with very few days off, at our various assignments within Scientology. I eventually became President of Religious Technology Center and, supposedly, the top “ecclesiastical” authority within Scientology. Richard was a high-level security officer. During this period my husband and I became intimately familiar with the structure and activities of various Scientology organizations. Among other things, I was briefed on and sometimes a participant in meetings involving litigation tactics and various


means used to attack and fight “enemies” of Scientology. In numerous instances I was in the chain of command or approval for such activities. The legal strategy of Scientology and the existence of numerous potential legal problems, some of which are set forth below, were known to me when I was a staff member in Scientology. Contrary to, what I understand to be claimed by defendants herein, Mr. Yanny did not reveal to me the legal strategies or secrets of Scientology. Nor did Mr. Yanny invent or open my eyes to the wrongs that I had suffered at the hands of Scientology.

4. I have become an “enemy” of Scientology. This has certain consequences that will influence what Scientology will do in this litigation. For example, it is important to understand that their value system allows dishonesty if done in the name of Scientology.

5. Enemies of Scientology are deemed to be “suppressive persons”(“SPs”). One becomes a “suppressive person” by doing a suppressive act, such as suing Scientology as a litigant or lawyer. In the jargon of Scientology, when one is “declared” this means that one has been declared a “suppressive person” and, therefore, may be, harassed, hurt, damaged or destroyed without regard to truth, honesty or legal rights. It is considered acceptable within Scientology to lie, cheat, steal and commit illegal acts in the name of dealing with a “suppressive person”.

6. This practice or policy is sometimes referred to as the policy of “fair game”. In the jargon of Scientology, a person who is “declared” is understood to be a suppressive person. This means that the person is “fair game”. The fair game policy was


issued in the 1960s. It was, never cancelled. A document was issued for public relations reasons that purportedly cancelled “fair game”; however, that document stated that it did not change the manner of handling persons declared “SP.” In reality, the purported cancellation of fair game is at most a matter of semantics. Enemies of Scientology are treated as “fair game.”

7. It is my understanding, and I have so testified in my deposition, that when my husband and I escaped from Scientology we were not immediately declared suppressive persons or subjected to the fair game policy. Among other things, we were compelled to do certain things and sign various documents to escape and avoid being subjected to fair game treatment. As we have now sued Scientology, we are “fair game”.

8. From 1984 through early 1987, I was President of Religious Technology Center (hereinafter “RTC”). As President of RTC and a Sea Organization member, I attended many meetings concerning the numerous legal actions involving Scientology organizations. During this time period, I had personal access to all legal documents having to do with RTC. I received a report every day on my computer that included a synopsis of each ongoing legal case involving Scientology. I received, or so I was told, copies of every major motion filed in cases involving Scientology. I was on the “approval lines” for legal documents dealing with RTC. During this time period, I had the option of attending legal meetings although some were mandatory. I attended many litigation meetings and became generally aware of Scientology’s dirty tricks and legal maneuvers. On specifics, I frequently deferred to in-house and outside counsel, however, at least in theory, I was


the head of RTC and had access to any business or litigation ” secrets” of Scientology.

9. As President of RTC, I was one of those responsible for retaining the services of Joseph Yanny as counsel for Scientology organizations. I supervised and worked with Mr. Yanny who served as coordinating attorney for RTC in 1985. I am not aware of any legal or corporate information concerning RTC that was available to Mr. Yanny but not available to me.

10. I am informed and believe that various Scientology organizations are contending that Mr. Yanny has somehow improperly educated me on the legal maneuvers, tactics and affairs of Scientology. Although such claims are consistent with litigation tactics of Scientology, which .are not constrained by considerations such as truth and reality, the proposition that I need Mr. Yanny to educate me on the internal affairs of Scientology is simply wrong. I was one of the highest ranking members of Scientology and was involved in upper management. Mr. Yanny was a lawyer hired by management, of which I was a part, to work for it. Further, it was the practice during the time period in question to screen the information given to outside counsel such as Mr Yanny.

11. It is the stated policy and practice of Scientology to use the legal system to abuse and harass its enemies. This crude, fundamental directive of Scientology is no secret. In any event, this information did not come to me from Mr. Yanny. The policy is to do anything and everything possible to harass the opposing litigant without regard to whether any particular motion or maneuver is appropriate or warranted by the facts or applicable law. That policy was followed in every legal case I was involved


with or learned about while a member of the Sea Organization. The management of Scientology consistently expressed and demonstrated a complete disdain for the court system viewing it as nothing more than a method to harass enemies. Some examples of this are set forth below.

12. During litigation between Gerald Armstrong and Scientology, which was before Judge Breckenridge of Superior Court for Los Angeles County, the court ordered the production of Armstrong’s pre-clear (“PC”) folders. These are files maintained by Scientology on those who submit to interrogation sessions in a process called auditing. During the course of that litigation I was ordered to go through Armstrong’s folders and destroy or conceal anything that might be damaging to Scientology or helpful to Armstrong’s case. As ordered, I went through the files and destroyed contents that might support Armstrong’s claims against Scientology. This practice is known within Scientology as “culling PC folders” and is a common litigation tactic employed by Scientology.

13. During other litigation in Los Angeles known to me as the Wollersheim case, I was told that the. judge had ordered the production of Wollersheim’s folders. As ordered, I “culled” these files. In other words, I removed contents that might have been damaging to Scientology or support Wollersheim’s claims against Scientology. For example, I removed evidence of events involving his family, the anguish this caused him, evidence of disconnection from family and evidence of fair game.

14. I was involved in numerous meetings concerning what is known to me as the Christofferson case in Portland, Oregon. This


case was tried twice. In the first case, a Scientology witness by the name of Martin Samuels was coached and drilled for hours on how to lie convincingly or avoid telling the truth. Before or during the second trial he admitted to this course of conduct. In this litigation, a Scientologist by the name of Joan Shriver produced responsive documents that may have been incriminating. This was a serious breach of policy for which she was punished. These documents were ordered produced on such short notice that apparently files were not thoroughly “culled”. In another case, Mr. Yanny was severely criticized and almost fired for failing to properly coach and feed the desired answers to Heber Jentzsch. Mr. Jentzsch was, for public relations reasons, the purported head of the Church of Scientology International. During his deposition, Mr. Jentzsch was unable to answer fundamental questions concerning the management of Church of Scientology International. This may be what certain defendants are referring to when they say that they were dissatisfied with Mr. Yanny’s services and I protected him. There were those, including McShane, who were outraged by the embarrassing testimony of Mr. Jentzsch. This was blamed on Mr. Yanny. I did not wish. to discontinue using Mr. Yanny at RTC for this perceived problem.

15. In November, 1985, I was present at a meeting whereat Earle Cooley, a Scientologist lawyer, Lyman Spurlock and Norman Starkey, all high ranking Scientologists, announced that they were going to contact Judge Mariana Pfaelzer. Earlier that day Judge Pfaelzer had denied a Scientology motion for a temporary restraining order. After losing on the application there was a meeting to determine what to do about the situation. At the


meeting Mr. Cooley had a file, that purportedly contained background and personal information on Judge Pfaelzer. During the meeting Mr. Cooley and the others announced that they were going to attempt to meet with Judge Pfaelzer that evening, at her house if necessary, concerning the litigation in which the temporary restraining order had been sought. Thereafter, Mr. Cooley and two others left with their file on Judge Pfaelzer. They returned several hours later at which time I was told that their attempts to contact Judge Pfaelzer had been unsuccessful.

16. In late 1979 and early 1980, there was a massive document destruction program undertaken to destroy any evidence showing that L. Ron Hubbard (“LRH”) controlled Scientology. I participated in this activity in Clearwater, Florida and am informed that there was also intensive document destruction at facilities in Gilman Hot Springs, California. From at least that point onward there was a continuous effort to hide or destroy any evidence of Hubbard’s control. For example, during an IRS investigation in 1984 and 1985, while in bed with pneumonia, I was ordered out of bed by Norman Starkey who told me that they had received a tip from a Los Angeles Police officer advising them of a pending IRS raid in Los Angeles. Mr. Starkey ordered me to go to a computer facility and insure that all information on the computers in Los Angeles that might show Hubbard’s involvement and control of Scientology’s money was destroyed except for one copy of each document. These copies were to be saved on computer discs which were to be hidden in secure storage places. At the time I was also instructed to destroy anything that would show the control of Mr. Starkey or Mr. Miscavige over Scientology.


17. I have been informed and believe that a an improper affidavit was filed in a case brought by L. Ron Hubbard, Jr. in Riverside, California. The circumstances were as follows: The document purported to be an affidavit of L. Ron Hubbard. The signature of Hubbard was purportedly notarized by David Miscavige. It is my understanding that this affidavit caused the case to be dismissed. Subsequently, I was told by Pat Broeker, who had been living with Hubbard at the time, and by Miscavige, that Miscavige had not seen Hubbard between 1980 and Hubbard’s death in 1986. Accordingly, the affidavit was apparently signed, notarized and dated during a time period when Hubbard was in seclusion and not seen by the person who purportedly notarized the signature of Hubbard.

18. In or about 1981, while working in a Scientology organization known as the Guardian’s Office, I had access to and observed various written and oral communications pertaining to illegitimate activities participated in by the Guardian’s Office.

The Guardian’s Office attempted to infiltrate both governmental and private agencies including the IRS, the Department of Justice, the American Medical Association and the National Institute of Mental Health. The purpose of this was to steal documents pursuant to Hubbard’s “Snow White” program. The goal of this program was to eliminate any negative reports about Hubbard and Scientology that may have been held by these various agencies.

19. While involved in Scientology I became aware of various operations directed against an author who had written a negative book about Scientology. The author, Paulette Cooper, was subjected to various forms of harassment. One operation included an


attempt to frame her. A false bomb threat was written. A Scientology agent lifted a fingerprint from Cooper’s apartment. These fingerprints were then transferred to the bomb threat letter. Ms. Cooper was subjected to an investigation and was not cleared until an FBI raid resulted in the seizure of Scientology documents that exposed the operation as a frame-up. There was at least one other operation directed against Ms. Cooper. The substance of it was to plant a boyfriend to reinforce and play upon her suicidal tendencies in the hopes that she would commit suicide.

20. In 1976 and 1977, the then Mayor of Clearwater, Florida, Gabe Cazares was involved with litigation against Scientology. Arrangements were made to have an attorney by the name of Merril [sp. Merrill] Vanniere [sp. Veneer?], a Scientologist, represent Mr. Cazares and sabotage his case. This plot was also exposed by documents obtained in an FBI raid of a .Scientology facility. Also, in response to Mr. Cazares’ litigation against Scientology, an attempt was made to implicate Mr. Cazares in a staged hit-and-run accident.

21. During the time period of my involvement with Scientology, I also learned of various. attempts to influence judges or force their removal from cases. For example, a private investigator named Dick Bast obtained a statement from a prostitute concerning involvement with a certain judge in Washington, D.C. who was sitting on a Scientology case. This was then publicized. The judge did not continue on the case. The same investigator, Dick Bast was also hired for the purpose of attempting to force the removal of a judge in Tampa, Florida. This involved what I know as the Burden case, which was civil


litigation brought by Michael Flynn. Dick Bast secured a yacht and attempted to get the judge on board for the purpose of filming him under compromising circumstances. The judge declined to go yachting and the operation was unsuccessful. Approximately $250,000.00 was spent on the operation.

22. I have been informed by Mark (Marty) Rathbun, a high ranking Scientologist, that his private investigator, Gene Ingram, “fed” a confession to Ala Tamimi when visiting him in an Italian prison. This false confession was, in substance, that Tamimi had been involved in a bad check scam involving an account of L. Ron Hubbard. This false confession implicated attorney Michael Flynn in the check scam. Michael Flynn was at the time considered a major enemy of Scientology because he represented numerous clients with claims against Scientology. This purported confession was used to slander and attack Michael Flynn. Michael Flynn has also been Scientology as part of its “strategy” for handling enemies.

23. During an IRS criminal investigation in the 1984 to 1985 time period, the IRS ordered production of various communications between Hubbard and Author Services, Inc. (ASI). The ASI staff worked literally day and night for several days reviewing documents so that unfavorable documents could be destroyed or otherwise concealed from the IRS. Lyman Spurlock and Marion M. Dendui, Scientologists involved in this operation, informed me of this operation. Also during this IRS investigation, my husband, Rick Aznaran, was ordered to remove and conceal any incriminating documents from certain locations. He was also directed to make the computer network “raid proof”. This involved creating a


system where incriminating documents could be deleted from computer storage rapidly and before the IRS could obtain control over the computers.

24. In 1985, I attended a conference on “squirrels” attended by Miscavige, Starkey, Spurlock, and McShane, members of top management, and others. In Scientology jargon, “squirrels” are people who use or practice some procedures also used by Scientology but who do not submit to the total control of the Scientology organization and, perhaps most importantly, who do not pay a percentage of their auditing or counseling fees to Scientology. At this meeting, David Miscavige ordered that public Scientologists be organized and motivated to physically attack squirrels and disrupt their operations. This was stated to be pursuant to the standard guidelines of Scientology. Pursuant to such directives, efforts were undertaken to intimidate and disrupt these persons and their organizations.

25. In 1981, operation “Juggernaut” was commenced. The purpose of this was to destroy Michael Flynn who, as stated above, was representing various plaintiffs with litigation against Scientology. This operation contemplated the use of infiltration, propaganda and attempts to persuade clients to turn against him.

26. The Guardians’ Office got into so much trouble, and worse yet got caught, that it was decided in the early 1980’s that the Guardians’ Office should be disbanded. This was purely a public relations gimmick. In short, it was decided that the Guardians’ Office and Mary Sue Hubbard, its then leader, were to take the rap for all criticism and improper conduct. This scheme was laid out in various written communications I observed in 1981


and 1982. (Of course, I was not allowed to keep or escape from Scientology with any such incriminating documents.)

27. Since the early 1970’s, Scientology has operated a forced labor camp known as the Rehabilitation Project Force (“RPF”). Staff members are incarcerated in the RPF for various real or imagined offense. People confined at this camp are forced to perform hard physical labor every day. They eat rice and beans, or left-overs, and wear rags. They are deprived of sufficient sleep. In 1987, I was confined in such a camp at Happy Valley for approximately six weeks. I worked all day and was confined in a room at night. To the best of my knowledge I was guarded 24 hours a day. They would not even let me shower alone. I had to obtain permission to use a bathroom. I was ill and not allowed to obtain medical treatment. I was not allowed to communicate with my husband nor was I allowed to obtain adequate sleep. I was told that I had gone insane and that my husband did not want to communicate with me. I was physically and psychologically abused both at Happy Valley and for numerous days thereafter in a process called “security checking”. Much oversimplified, I was grilled on a primitive lie detector called an E-Meter and made to understand that I would not be released, have my property returned, or escape fair game policy unless I eventually gave all of the “right” answers. Examples of ” right” answers were responses that I would not talk to a lawyer or consider suing Scientology. I had to give such answers before being released.

28. Recovering from the years of brainwashing, thought control and propaganda to which Scientology subjected me is a


gradual process that I do not fully understand. I am not a psychologist or psychiatrist and do not fully understand the ramifications of what I have been through although I can observe and experience many symptoms. I have many nightmares and a fear of Scientology.

29. The suit brought by Richard Aznaran and myself is based upon real events that happened to real people, namely us. Just as my husband and I do not need Mr. Yanny to educate us on any secrets of Scientology, it is simply untrue that our claims were somehow invented or manufactured by Mr. Yanny. The whimsical notion that Mr. Yanny invented this litigation through my husband and me is simply false.

30. My husband and I consider Mr. Yanny to be a friend. Further, it might be noted that Mr. Yanny was to serve as my personal counsel in a class action against Scientology and numerous individuals including myself. Recent events have changed this, however, .there was a period of time when Mr. Yanny was purportedly designated as my personal counsel with the approval of Scientology.

31. My husband and I feel quite strongly that we want Barry Van Sickle and the firm of Cummins & White to represent us in this case. Our reasons are both subjective and objective. We do not wish to list our subjective reasons, although we will do so if the Court requests it. Objectively, it might be noted that we had considerable difficulty finding counsel willing and in a position to undertake this extremely volatile, time consuming and expensive litigation. We are unable to pay hourly rates to pursue our claims and need a firm willing to work with us on a contingency


fee basis. I anticipate great difficulty, delay and prejudice if forced to find other counsel.

32. Based upon my experience within Scientology and as a litigant against it, I understand that this is not routine litigation. If I am forced to find other counsel, prospective counsel will be presented with the following situation:

(a) A complex case that must be handled on a contingency fee and cost-advanced basis;

(b) A case that requires a litigation team and substantial financial resources;

(c) A case involving an opponent who has a practice and history of suing opposing lawyers as a tactic in addition to subjecting opposing lawyers to surveillance, depositions, infiltration, bad publicity and the full ramifications of the fair game policy;

(d) A case where the opponent is not constrained by a need to be cost effective, truthful, honest or reasonable; and

(e) A case that requires extraordinary security precautions.

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

Executed this 9th day of August, 1988, in Dallas, Texas.




  1. This document in PDF format.

Scientology v. Armstrong: Reporter’s Transcript of Proceedings (August 2, 1984)






NO. C 420153

August 2, 19841


For the Plaintiff and Intervenor: LITT & STORMER
3550 Wilshire Blvd. , Suite 1200
Los Angeles, California 90010
For Plaintiff Only: PETERSON & BRYNAN
8530 Wilshire Blvd. Suite 407
Beverly Hills, California 90211
For the Defendant: CONTOS & BUNCH
5855 Topanga Canyon Blvd.
Suite 400
Woodland Hills, California 91367
Official Reporter
Certificate No. 644


[THE COURT:] Again, I can’t say the action was brought in bad faith or for any kind of improper purpose as such. It is a mixed bag. Some of the things they did were wrong. Some of the things they did they had a right to do, and I cannot under those circumstances find that the defendant is entitled to attorneys’ fees on that theory.

So, the nuts and bolts of this is that I have to deny this motion. I do it with a certain amount of reluctance because I feel that the defendant’s counsel have served long and hard and put a lot of time in here and effort to be of assistance to their client. They have served their client well. There is no immediate reward for them in this case in the sense of even compensating them for their time.

They have labored against tremendous odds, against tremendous financial resources. The financial resources on the other side are overwhelming, but I don’t feel I can in any legal basis grant the motion.

There is one last thing I want to mention, and that has to do with the declaration of John G. Peterson on this opposition to motion for attorneys’ fees.2

As Mr. Peterson has indicated, he has become emotionally involved in this case, and it is rather abundantly clear. So some of his comments which have been reported in the newspapers — he can make whatever comments he wants to about the case or the court or anybody else. It doesn’t bother me, but when he puts in a declaration what really is just an argument as to why the motion should not be granted, it seems to me that it is totally unprofessional.

I have to contrast it with the response from Mary Sue Hubbard which I thought was a very professional response, obviously by people who are disappointed in the outcome of the litigation, but at the same time they proceed in a lawyer-like fashion.

This attaching of these exhibits relating to Mr. Flynn, to me, is the worst kind of tactic. It is an effort to smear Mr. Flynn. For what purpose I don’t really know, gratuitous insults to inject into the file of this case some dirt, I suppose, for the obvious purpose of prejudicing Mr. Flynn or any court or any person who might review the record.

Now, obviously if there is any substance to these allegations, they should have been presented to law enforcement authorities.

MR. PETERSON: They have been.

THE COURT: If they conduct investigation and find any merit, I am sure they will do whatever they feel is appropriate.

At the same time, I have been around criminal defendants, both as a defense lawyer and a judge, for many, many years, and I tend to be very skeptical about what any person in prison is likely to say, either about his former lawyer or associate of a former lawyer or upon anything which might provide him with some secondary gain. I can’t help but approach this with a great of skepticism and cynicism.

I read some of the exhibits dealing with Black Propaganda.

I got a letter from some woman about dead agenting. Said I was probably the subject of now being a dead agent myself, and I really couldn’t care less. But I think it is unfortunate that the flle has to be cluttered up with, I am going to say it right here, garbage of this type. I don’t think this should be a part of the public record.

I am going to order that the documents which purport to be exhibit B through F be separated from this declaration, be enclosed in a sealed envelope, and be ordered sealed and not to be opened except upon further order of any court that wants to review this matter. Nothing to do with this lawsuit. Nothing to do with these motions, and I think it is offensive and I am quite surprised.

End of that.



  1. Retrieved from Armstrong 1.
  2. See Declaration of John G. Peterson (July 30, 1984).

OSA Press Release (June 25, 1984)

Source  “PR Newswire”
Author  Heber Jentzsch
Date  June 25th, 19841

LOS  ANGELES,  June  25/PRN  –  Church  of  Scientology  attorney  John  Peterson
announced  Friday  that  he  had  filed  a  notice  of  appeal  with  the  Superior  Court  of
California and an emergency application for stay pending the appeal of a decision issued
June 21 by Superior Court Judge Paul Breckenridge.

Breckenridge issued a memorandum of intended decision in a suit brought by the church
and  Mrs.  L.  Ron  Hubbard  against  a  former  church  employee,  Gerald  Armstrong,  for
unlawfully  taking  thousands  of  pages  of  valuable  documents  and  personal  papers
belonging to Scientology founder L. Ron Hubbard and Mrs. Hubbard.

The decision, according to Peterson, “was completely ludicrous. On the one hand, it is
clear that the trial court found there was an invasion of privacy and conversion of the
documents and papers by Armstrong for purposes other than those for which they were
entrusted to him. Yet, the trial court ordered that the personal and private documents be
unsealed and made available for public access.

“Under this decision,” Peterson said, “any person or institution – religious or otherwise –
is no longer safe from anyone just coming along and stealing their personal effects and
then exposing them to public view.”

According  to  the  emergency  application  to  the  California  Appeals  Court,  Peterson  is
asking the court to maintain an earlier injunction against the public use or inspection of
the documents taken by Armstrong.

Peterson  went  on  to  say  that  “since  the  Superior  Court’s  unsealing  order  materially
dissolved  the  prior  injunction  and  changed  the  status  quo,  a  stay  by  the  appeals  court
seems mandatory.

Contact – John Peterson at 213-386-4303, 213-661-2747 or 213-654-8064 for the Church
of Scientology, or after hours Rev. Heber Jentzsch of the Church of Scientology at 213-