Supplemental Memorandum In Support of Defendants’ Motion To Dismiss Complaint With Prejudice […] 1
That Armstrong is amenable to the kind of covert representation in which Yanny is engaging in this case is highlighted by his recorded remarks made in November 1984. At that time, Armstrong was plotting against the Scientology Churches and seeking out staff members in the Church who would be willing to assist him in overthrowing Church leadership. The Church obtained information about Armstrong’s plans and, through a police-sanctioned investigation, provided Armstrong with the “defectors” he sought.2 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 the Church).3 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 the Church 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 document sitting in front of them and then —
ARMSTRONG: Fucking say the organization destroys the 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. Farny, para. 6.) With such a criminal attitude, Armstrong fits perfectly into Yanny’s game plan for the Aznaran case.