In my May 31 2009 letter to you, I brought up the incident of Scientology agents breaking into my car in 1984 and stealing a bunch of my things, and Miscavige’s having them after their theft. I asked for your help getting them back; in fact I wrote the whole letter essentially asking for your help in righting years of wrongs Sea Org personnel under Miscavige, including you, have committed, and continue to commit, against me – and yes, many, many others.
Oh, now that I’ve mentioned it in the above list of Fair Game attacks on me, I’ll also ask you about the theft of my original manuscript, artwork and other materials from my car. I know from both Vicki Aznaran and Jesse Prince that Miscavige actually claimed to them that he had these things in his possession after they were stolen my car, which was during the Armstrong videotape operation in the fall of 1984, so I trust you won’t pretend the theft didn’t happen. Just help me get my things back from Miscavige, okay? 1
After writing you, I remembered that Jesse Prince had told me that both Miscavige and you had told him about having my things after their theft. I also found this from a 1999 letter to Miscavige that I posted to a.r.s.:
You will recall that a cult operative broke into the trunk of my car in 1984 and stole my briefcase which contained about 300 original pages of my art, almost all handwritten or drawn. You will recall that my attorney Julia Dragojevic wrote to the org demanding return, and that your org attorney John Peterson answered, denying the theft and possession of my things.
Recently I had the happy opportunity to talk with Jesse Prince about all this. Jesse stated that while inside he too was told by both you and Mark Rathbun about your agent’s theft of my things from the trunk of my car and your having possession of them. Jesse recalled you describing my work as weird writing. You stole them, you know where they are and you can put your hands on them. Now get them back to me, and be known thereuntil as a thief.
I’m aware that you could be another Loyalist op, Mark, but I’m taking you for now at face value. So far, on its face, what you’ve said, and to me not said, indicates that in the Scientology v. Gerry Armstrong war, you are on the cult’s side.
Accepting what you’ve said about yourself, it isn’t easy for you to do what’s necessary to change that indication. I think, however, that if you start by debriefing about the 1984 theft of my things and what happened with them, and doing what is within your power to help me get them back from Miscavige, you’ll get the necessary courage.
It’s almost 25 years since my things were stolen. Following Vicki’s and Jesse’s debriefs to me about Miscavige possessing my things, I’ve written him and other Scientologists many times, requesting my things’ return. Doubtlessly you saw some of those requests in your years inside.
You knew John Peterson lied in his denial of Scientology’s knowledge of the theft. He was, of course, your organization’s front attorney just because he would willfully lie and would help Fair Game his clients’ victims.
I’d bet you knew about someone in the LAPD altering/losing my police report. These documents on the incident could refresh your memory: http://www.gerryarmstrong.org/50grand/cult/scientology-theft-manuscript.html
My manuscript and original artwork, and every other piece of paper, are very valuable to me, and Miscavige, you, and many other Scientologists have known of their great value to me. Consider the nature of a group that would willfully inflict that pain on an individual all these years. It’s cruelty, Mark. And it’s an ongoing crime that should be confronted, stopped and expiated.
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
them. My knowledge based on documentation and observation, is that the major reason for Mr. Hubbard’s calling Scientology a ‘religion,’ in addition to tax evasion, is to hide behind Constitutional guarantees for religions and so carry out his scheme of mind control to keep his followers duped. He has systematically and knowingly lied to and defrauded his followers, kept them from finding out the truth or becoming free with cruel and bizarre treatment, as for example with the RPF, and kept them economically and mentally suppressed, while he made millions of dollars from their labor.”
The Court touched on mind control in the decision in the document case:
….the Church or its minions is fully capable of intimidation or other physical of psychological abuse if it suits their ends. The record is replete with evidence of such abuse.”
And common sense yields only mind control as the explanation for the years of submission to the abuse. The organization has known of its own practices for decades, has known for over four years that I defined some of those practices as mind control, and has known for over two years that the Court considered “psychological abuse” and Hubbard’s “controlling, manipulating….his adherents” part of this case. Mind control is not a new subject which would require of the organization a new defense or more time in which
to create it.
3) Regarding continuing the trial of the cross-complaint until issuance of the Appeals Court decision in the document case, it was cross-defendant organization which moved to sever the cross-complaint as unrelated to the underlying document case.
4) In the document case, for a trial that lasted thirty days, because the organization insisted on an expedited trial, I had twenty months in which to prepare for my defense. From the time of filing of the cross-complaint until the present trial date, the organization will have had fifty months. The organization has taken my deposition at least twenty-five days, and has taken the deposition of virtually everyone connected to me at some point in this litigation. Each person on this side whom the organization has sought to depose has complied and has answered any relevant questions. My attorneys advise me that because of the organization’s compartmentalization and obstructionist tactics, taking any organization depositions is a costly and frustrating waste of time. The organization knows virtually ever fact of my life since I was born which has any connection at all to the issues in the cross-complaint; there is nothing left to discover. Discovery by the organization is for this reason, and because of attorney tactics and behavior, largely harassive. The extension of discovery is just the extension of harassment.
5) The organization cannot honestly argue that it was prevented in any way from getting whatever discovery it has wanted or from getting its many motions, several of which were in fact obstructive of legitimate discovery, heard by this Court. The organization has used 12 law firms in this case, and these attorneys have all been involved in other Scientology litigation and have deposed all my potential witnesses in those cases in addition to this. In addition to the staggering sums paid to attorneys to litigate this case, the organization has paid at least hundreds of thousands of dollars for PI’s, for intelligence operations and for media black PR campaigns against me. Where it could not wait for legal discovery, it stole my documents. And as shown in my earlier declarations, it has, through perjury and manipulation, thwarted my discovery into its clear cut and egregious invasions of my privacy and assaults on my mind.
6) The organization has demonstrated continually throughout the litigation of this case that truth, which must have some relationship to legitimate discovery, is, as far as the organization is concerned, irrelevant. Attached hereto as Exhibit C is a copy of a recitation of a dream I had in March 1985. I have blacked out for this purpose, anything which could be considered offensive. Donald Randolph has, in furtherance of the organization’s goals, defined the recitation of the dream a “sickening work” demonstrating my “extremely aberrated activities.” The dream was a dream. The recitation was true, and as artistically tight as I was capable of. To the
organization, if it suits its purposes, however, dreams are reality, and truth is whatever can be twisted therefrom. The only thing “sickening” about the dream is how the organization acquired it and went about its degradation. I sent it to my friend Dan Sherman, a professional writer who had throughout 1984 encouraged me to write and who had “critiqued” some of my work. Sherman was, of course, being operated by the organization in the “Armstrong operation” (the same operation which John Peterson says never happened), and Sherman either gave the organization the “dream” he had dutifully tricked me into sending him, or the organization simply stole it from him. Attached hereto as Exhibit D is a letter from Sherman from March 1986 in which he indicates that the organization was indeed getting his mail. Since writing to me, however, Sherman has apparently again been pressured by the organization because he has again cut communication with me and gone into hiding.
Another example of organizational perversion of truth is the whole Armstrong operation. A group of individuals fearing for their lives and asking me for help to reform the organization became in organization black PR campaigns my attempt to destroy religion. Efforts by the organization to enveigle me into illegal acts became my commission of the acts. Use of my pc files as a lure to entrap and ruin me is characterized as protecting the sanctity of auditing. The organization needs no more discovery since it creates “truth” and “evidence,” as it wishes.
7) All the discovery the organization has sought can be completed in the next two. weeks. I have been answering interrogatories, in addition to all the other work I must still do, and despite the fact that none of the interrogatories cover anything which I have not already testified about, and I will complete them by November 26, 1986. The organization took my deposition on October 29 and 30 and they can have my deposition another day before trial if they want. They have made no request to set a date for the continuation of my deposition since the two days in October. The organization, just to delay the trial, should not be permitted to delay the discovery opportunities it has.
8) Although the organization is clearly not harmed if the cross-complaint goes to trial January 19, I will be if it doesn’t. Through all the operations, the lies and attacks over more than four years, the hope of going to trial has been a major stabilizing factor in keeping me going. I do not have the extra legal options which the organization does; my only opportunity to resolve this protracted, bitter and emotionally devastating war is at trial. My life has been radically altered by the organization’s acts: the threats, the assaults, the pc file perversions, the obstruction, the lies, the operations, the betrayals, the terror. The intensity has fluctuated and there were brief periods when my life moved toward normalization, but always briefly as another organization attack was never far away.
Since the July pc file culling, however, there has been no respite. The anguish I feel just about every day may be a blessing because the emotional ripple does not manifest itself in other more destructive ways. But I cannot feel that it is optimum or normal or healthy; that is, I’m under a ton of stress. I have grappled with the litigation and the extra-litigation threat in many ways. Some of them, even within the observable context of Gerald Armstrong, and even to myself, are bizarre.
Almost the whole day now, and day after day, is connected to this subject. Sometimes I feel like my body is a battleground. Outside my apartment and office, and those are just about all my destinations, I am most of the time aware of the cold evaluation of threat. I am intellectually sound enough to realize that to succeed in getting the cross-complaint to trial raises the potential for a really serious operation. The emotional ramifications which follow from that are what I deal with. That is, the alteration of the circuitry. The lessening of the threat can only be achieved, however, by going forward, even though what could happen at trial could be beyond anything I’ve yet experienced. All the operations have had the ultimate goal of stopping me from proceeding to trial. They have only succeeded in convincing me that the only way the war and the threat can end is to get to trial.
Executed this 18th day of November, 1986 at Boston, Massachusetts.
I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct.
PETERSON & BRYNAN
ATTORNEYS AT LAW
8530 WILSHIRE BOULEVARD, SUITE 407
BEVERLY HILLS, CALIFORNIA 90211
ATTORNEYS FOR: Plaintiff ,
CHURCH OF SCIENTOLOGY OF CALIFORNIA
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
CHURCH OF SCIENTOLOGY OF CALIFORNIA,
MARY SUE HUBBARD,
CASE NO. C 420153
DECLARATION OF JOHN G. PETERSON IN OPPOSITION TO MOTION FOR ATTORNEY’S FEES
TIME: 8:00 a.m. Defendant.
I, JOHN G. PETERSON, declare:
1. This declaration is submitted in opposition to defendant’s Motion for Attorney’s Fees, pursuant to Code of Civil Procedure Section 1021.5. Plaintiff, CHURCH OF SCIENTOLOGY OF CALIFORNIA, joins in and adopts by reference the Memorandum in Opposition to Motion for Attorney’s Fees filed herein by intervenor, MARY SUE HUBBARD.
2. Defendant’s motion can best be described as a poor attempt to add insult to injury. The defendant’s moving papers are an affront to the intelligence and integrity of this Court and the legal profession. This fee request is an insult to good intentioned legislators who enacted Code of Civil Procedure Section 1021.5, and is ironic since this case was pursued by GERALD ARMSTRONG’S attorneys primarily to use this Court as a discovery tool for other litigation and as an avenue for media coverage to extort settlement of other litigation against Mr. Hubbard and the CHURCH.
3. GERALD ARMSTRONG’S moving papers transparently and despicably use a quote from the Bible and a reference to Jonestown all on the front page. The papers go on to paint GERALD ARMSTRONG as a great protector of truth who risked life and limb to expose the “illegal and unconstitutional actions” of the plaintiffs all to a “significant public benefit and will further constitutional freedoms.” However, nowhere does GERALD ARMSTRONG ever state exactly what these public benefits are and how the fact that he stole documents and invaded a person’s privacy can further constitutional freedoms.
4. GERALD ARMSTRONG’S unsupported claims of public benefit should not come as a surprise since all of his trial allegations were never supported by evidence. GERALD ARMSTRONG’S attorney, on page 9, lines 20 through 28, and page 10, lines 1 and 2, attempt to explain the claim for public benefit and constitutional significance. After reading these lines several times, anyone with any first year of law school education would be compelled to conclude: (I) It is incoherent; (2) the person writing the lines does not understand constitutional law; (3) the person writing these lines is audacious in seeking fees for “legal” work; and (4) any response is impossible and would only dignify the lines by educating the person who wrote them.
5. The Court should examine what the attorneys for GERALD ARMSTRONG really sought in this case. They argued that there was a novel and heretofore unheard of in law defense called “justification”. This is, GERALD ARMSTRONG because he believed his life was in danger and that “harassing lawsuits” were forthcoming he could steal evidence and send it to his lawyer for use in this “potential” litigation. Defendant’s attorneys also asserted that if a person feels he may be physically harmed, he can steal materials and threaten to or even publicize these private materials as a deterrent.
6. While these purported “defenses” advocate the worst kind of lawlessness and vigilantism, defense counsel totally failed at trial to produce any evidence to support these novel defenses. First, GERALD ARMSTRONG had no reasonable belief he was going to be sued. ARMSTRONG himself testified that he knew of no one who had ever left the CHURCH and been sued. It is unreasonable to conclude and foolish to believe that the incident where his ex-wife told him to “get a lawyer” could mean anything other than advice that if ARMSTRONG wanted the photos returned, ARMSTRONG would have to sue the CHURCH. How strange that this is the person found to be fearful of his life and terrified of this organization, yet he was marching up to the CHURCH’S main offices shouting and demanding “his pictures”. Did defendant produce witnesses who said they had left the CHURCH, been critical and then been sued? No evidence was produced at trial, simply because none exists. The only thing the Court heard was the ravings of Flynn.
7. The only reasonable way to view the evidence clearly shows that GERALD ARMSTRONG stole the documents for use in his case against the CHURCH. He left the CHURCH, was unskilled, had no job and he visited Flynn, a notorious anti-Scientology plaintiff’s lawyer, who obviously conspired with ARMSTRONG to steal the documents for use in their cases. It is naive to think that ARMSTRONG’S massive theft of marginally relevant documents is simply overkill. That is also why Flynn argued so strenuously that the Court do his discovery for him and hold the documents for use in the Cross-Complaint and other litigation Flynn is involved in.
8. Defense counsel claim they have exposed the CHURCH’S policy of blackmailing former members by use of PC material (page 4, lines 9 through 10). Flynn argued that the CHURCH blackmailed people. However, no witness was ever produced who testified that they had been either threatened with or blackmailed by the CHURCH. Defense counsel, without legal support or evidence, asked this Court to find that the CHURCH practices this policy. Also, how could ARMSTRONG reasonably fear blackmail when he had no knowledge of any instances of it prior to his theft of the documents?
9. Defense counsel should not be compensated for conducting a heresy trial. This Court took judicial notice of the fact that Scientology is a religion and has rights under the First Amendment. This Court correctly ruled that it could not inquire into or evaluate the merits, accuracy or truthfulness of Scientology. Yet defense counsel sought to try the religion, its Founder and its policies. An example of the dishonesty of defense counsel is when they submitted to this Court Exhibit 500-HHHHH. This 1970, French Government investigation report was authoed by an ex-Nazi, who admitted doing no first hand investigation but relied on other sources. Also, defense
counsel failed to inform the Court that the French court had reversed its findings that Scientology was a fraud.
10. Julia Dragojevic’s dishonesty with this Court is shown by her Declaration. At the beginning of the trial, she said that GERALD ARMSTRONG needed Flynn because Flynn knew the case better, was more experienced and knowledgeable; and we were told she had never tried a jury case. Now she is the “Scientology expert” who is deserving of $150.00 per hour. She is even claiming $150.00 per hour for the time she just sat in the Courtroom during Flynn’s trial. Julia Dragojevic’s hours are inflated, refex time spent on other matters and not relevant to this case (see attached Exhibit “A”).
11. Attorney fees could not be properly claimed because GERALD ARMSTRONG thinks he exposed Scientology and L. Ron Hubbard as frauds. This Court clearly ruled in the beginning of the trial that Scientology was not on trial and that the Court would not consider the truth or falsity of the contents of the documents but only how they were relevant to ARMSTRONG’S “state of mind.” If the Court correctly followed this stated ruling, it could not properly reach any conclusions regarding Scientology or L. Ron Hubbard, and defense counsel could not receive fees for this improper presentation.
12. At the beginning of the trial, plaintiff’s counsel warned the Court about allowing Michael Flynn to conduct the trial. Plaintiff made a motion to disqualify Flynn. Plaintiff warned this Court that Flynn would conduct a heresy trial against the CHURCH and a personal attack against L. Ron Hubbard. Flynn did this under the pretext that he was going to show this person and organization had unclean hands and was not entitled to equitable relief. Defense counsel argued that an old order by MARY SUE HUBBARD (GO-121669) gave her unclean hands that should deny her relief in this case. This ridiculous legal position is so contrary to black letter law that it does not deserve further comment. What is incredulous is that defense counsel seeks fees for presenting and arguing such a patently unsupported legal position.
13. Defense counsel point repeatedly to what they call the unclean hands of plaintiffs. This Court should be aware of the true character and motives of Michael J. Flynn.3
14. Plaintiff can not ignore Flynn’s efforts to prejudice this Court. Plaintiff also asks the Court to admonish counsel for defendant and their client to immediately cease these improper tactics, such as filing this fees motion, in their effort to prejudice this Court. Plaintiff also requests the Court to impose sanctions in the amount of attorneys’ fees incurred by plaintiff in replying to this frivolous motion for fees.
15. According to sworn declarations filed by attorney Michael J. Flynn of Boston, Massachusetts, he is an attorney of fourteen years experience in the State of Massachusetts who has tried 40 to 50 jury trials since 1972. Approximately one-third of Mr. Flynn’s career, since mid-1979, has involved litigating against the Church of Scientology and/or its Founder, L. Ron Hubbard. Mr. Flynn has been counsel of record, or counsel but not of record, in cases being litigated in at least the states of Massachusetts, New York, Florida, Nevada, Oregon and California involving the Church. He has made appearances as counsel pro hac vice in California three times in the past two years in suits involving either Mr. Hubbard or the CHURCH.
16. Due to Mr. Flynn’s legal attacks upon the Church of Scientology, its members, practices and Founder, investigative actions were undertaken by professional investigators. These investigations revealed the following facts:
17. In early 1981 a document that laid out a scheme to sell shares in litigation against the Church of Scientology was drawn up in the law offices of Michael Flynn in Boston.
18. This document referred to Flynn Associates Management Corporation, a for-profit Massachusetts corporation incorporated on August 28,1980 by Kevin Flynn, Michael Flynn and Cheryl Flynn. (See attached Exhibit “B”). Kevin Flynn is the brother of Michael Flynn and, at that time, worked as an investigator or researcher for Michael. Cheryl Flynn is Kevin Flynn’s wife.
19. The document stated: “Description: Flynn Associates Management Corp. is a management consultant company. It was organized to manage and oversee the operations and strategy of all Scientology litigation of Michael Flynn Associates.” (See attached Exhibit “C”). Other documents discarded at about the same time from Mr. Flynn’s office revealed that investors were to be promised “a $2.00 return for each $1.00 invested.”
20. Despite claims to the contrary by Michael Flynn, attempts were made to sell shares. In an affidavit executed on October 13,1981, Jim Grey of Clearwater, Florida, stated that on October 2, 1981, Michael Flynn “offered me the position of Trustee of Flynn Associate Management Corporation (FAMCO) in the Clearwater area and told me that as a trustee, I would receive, raise and disburse monies which would be used to file suits against the CHURCH OF SCIENTOLOGY around the country and therefor breack the CHURCH financially. ” (See attached Exhibit “D”).
21. A FAMCO document obtained around the same time, entitled “Scientology – Review and Planning”, demonstrated that the above was an “All Out” strategy which included: “a) closing orgs (orgs -Scientology organizations) b) adverse media c) adverse public d) Fed & State attacks”. Following this “all out” strategy, Michael Flynn and FAMCO engaged in the “adverse media” actions. From the deposition testimony of both Kevin Flynn and deprogrammer Joseph Flanagan in Garrison v. Kevin Flynn, et al. and Miller v. Kevin Flynn, et al. the initiation of the “adverse public” strategy was also implemented with the creation of new potential litigants. Kevin Flynn operating out of the 12 Union Wharf offices of FAMCO and Michael Flynn, solicited, organized and carried out several “deprogrammings” of Scientology parishioners. Following each successful deprogramming, Kevin Flynn had the victim transported to the Boston offices of Michael Flynn where the person was solicited to join the suits filed against the CHURCH they had just departed.
22. This all out effort continued on into early 1982. Affidavits show that through co-conspirators, Michael Flynn obtained access to the Bank of New England where Church of Scientology Founder L. R. Hubbard maintained a Cash Reserve Management account. The conspirators obtained copies of several of Mr. Hubbard’s checks, as well as several checks from an unrelated Florida company, and hired Ala Fadili Al Tamimi to counterfeit and forge these checks in the amount of $2 million.4
23. In a sworn statement, Ala Tamini has detailed how Mr. Flynn promised him $400,000 to pass the forged checks and pass the monies received to an overseas account established by Mr. Flynn in the Cayman Islands. Mr. Tamimi also related, in this same statement, the treatening remarks made by Mr. Flynn regarding the safety of Mr. Tamini’s family. (See attached Exhibit “E”).5
24. Following the failure of the attempt to forge and pass Mr. Hubbard’s checks, Mr. Flynn then filed suit on behalf of Ronald DeWolf, the estranged son of Mr. Hubbard, in Riverside, California. The suit claimed that Mr. Hubbard was a missing person under California probate codes and included charges that Hubbard’s business affairs were being mismanaged as evidenced by the failed attempt to forge one of his checks. Flynn accused Church officials of forging the check.
25. The investigation also discovered evidence that such behavior by Mr. Flynn was not limited solely to litigation against the CHURCH.
26. According to the Declaration of George Edgerly, executed on March 5, 1984, in Bridgewater, Massachusetts, Mr. Flynn both offered to pay Edgerly for his silence during two 1976 trials and made intimidating statements regarding the safety of Mr. Edgerly’s children.6
27. Mr. Edgerly was the defendant in a criminal case for fraud in Lowell, Massachusetts, in February and March, 1976. In approximately March, 1976, Mr. Flynn approached Mr. Edgerly and suggested that Edgerly not testify in his own defense, offering to pay Edgerly’s wife $500.00 a week for every week that Edgerly spent in prison. Edgerly accepted this proposal, was paid $1,000.00 by Mr. Flynn about two weeks later, and was sentenced to three to five years in prison.
28. Between October and December, 1976, Mr. Edgerly was again on trial, this time as a defendant to a charge of conspiracy. One of his co-defendants was represented by Mr. Flynn, both in this criminal suit and in a civil suit against General Motors Corporation.
29. Again, during this trial, Mr. Flynn proposed to Edgerly that he not testify and Edgerly agreed. Mr. Flynn promised Edgerly a share of the recovery from General Motors in exchange for his silence.
30. Later, during the trial, subsequent to Mr. Edgerly’s attorney being removed for a conflict of interest and Edgerly beginning to represent himself, Edgerly decided that he was being set up as the “fall guy” by Mr. Flynn and his co-defendants. He began aggressively cross-examining his co-defendants. They, and Mr. Flynn, became upset by this, resulting in Mr. Flynn’s offering to pay Edgerly $18,000.00 immediately. The money was not immediately forthcoming; Edgerly continued his aggressive cross-examination; and Mr. Flynn then mentioned that he knew of Edgerly’s concern for his family, that he knew Edgerly had a lot of children who were little and that “one of
them could be hit by a car.” Mr. Flynn made similar threatening remarks to Edgerly’s wife. (See attached Exhibit “F”).
31. A fee request by defense counsel is not supported by law as more fully discussed in the Opposition filed by intervenor. A request for fees is inappropriate in this case because of counsel’s conduct of this litigation and other attacks on Scientology. It is plain to see that this litigation was not brought and pursued for any public interest, but was part of a general plan of attack on Scientology and an attempt by Flynn to get documents for use in his
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed on July 30, 1984, at Beverly Hills, California.
JOHN G. PETERSON
- Judge Breckenridge discussed this declaration at an August 2, 1985 hearing in Scientology v. Armstrong: Reporter’s Transcript of Proceedings (August 2, 1984) ↩
- This document in PDF format. ↩
- See Operator: John G. Peterson. ↩
- See Scientology’s Check Forgery Frame. ↩
- See Declaration of Ala Fadili Al Tamimi (May 5, 1984). ↩
- See Operator: George Edgerly ↩