DECLARATION OF GERALD ARMSTRONG¹

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

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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

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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.

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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

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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.
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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.

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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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Notes