§   What's New  ||  Search   ||  Legal Archive  ||  Wog Media  ||  Cult Media  ||  CoW ® ||  Writings  ||  Fun  ||  Disclaimer  ||  Contact  §

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6251]

DECLARATION OF GERALD ARMSTRONG

 

I, Gerald Armstrong, declare:

1. I have been informed by my attorney, Julia

Dragojevic, that attorneys for plaintiff Scientology organization

have advised her that they intend to tell the Court that the

organization has now fully complied with the Court's orders

of July 2, September 9 and December 9, 1985 regarding production

of documents. The purpose of this declaration is to show that

the Court's orders have not been complied with.

2. I have reviewed the documents received from

plaintiff organization as my "B-1" file. This is offered by the

organization as full compliance with original requests for

production:

2. All originals and all copies of Guardians Office

files pertaining to Gerald Armstrong.

3. All originals and all copies of correspondence

of the Guardian's Office pertaining to Gerald

Armstrong.

Attached hereto as Exhibit [A] is a 14 page "time track" or

chronology produced as part of the B-1 file. I have circled

in red the date of 87 time track entries for which the documents

from which they were extracted have been deleted from this "B- 1

file."

3. "B-1" was a designation, known from a certain level

upwards in the organization, for the Guardians Office

.intelligence bureau. B-1 gathered intelligence internally and

externally and overtly and covertly, and it ran agents and

-1-

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6252]

carried out operations against enemies to frame them, compromise

them, orotherwise nullify them as a threat. The GO also ran

public relations, finance, legal, and they had, except for a

couple o£ L. Ron Hubbard's personal public relations officers,

total control of any organization interfacing with government

agencies, the media, law enforcement, private investigators, and

enemies. The only thing the GO did not run was the auditing-

training income-making apparatus of the organization. And that

part of the organization would have no files on me. Within the

GO each bureau had its own files. These files often related to

enemies. "Freedom," the organization's tabloid black PR tool,

was part of the GO. And the GO was itself a part and function

of the Church of Scientology of California corporately and it

was operated by Hubbard through his wife, the Controller. There

has been a continuity in GO activities, and in many cases

personnel, right to present time. The organization still puts

out"Freedom," it still does PR and black PR, it hires private

investigators, lawyers, graphologists, etc., it has a finance

bureau , and it has intelligence data gathering and covert

operations; and it has files on me in each of these areas.

Different organization units performing these functions from

1982 onward include Special Project, ASI, Religious Technology

Center (RTC), Office of Special Affairs (OSA) (which is divided

into OSA Pac(ific), OSA US, OSA Int(ernational), etc.), Mission

All-Clear (MAC) (also with local, continental and international

units), Commodore's Messenger Organization (CMO) units, Watch-

Dog Committee (WDC), and possibly others unknown. The corporation

name personnel in these units supposedly worked for was

-2-

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6253]

irrelevant since Hubbard, the GO, and the messengers who took

over the GO functions in 1981 by-passed all corporate lines.

The last time track entry in the "B-1" file (see Exhibit [A]) is

June 15, 1982. The organization had already begun its PI

surveillance of Jocelyn and me, yet there is no time track

reference to the PIs or their product. That the organization's

intelligence bureau was not running the PIs and not getting

their product is a laughable impossibility. The real GO files

on me, as for major enemies, would have been started in 1982.

Before then there would have been an accumulation of some

materials in my "B-1" file, notably everything from the three

weeks I was locked up on Hubbard's order in B-1 at GO US in 1976,

but even this plaintiff organization has failed to produce. In

the spring and summer of 1982 the organization escalated the

attack against me--- the PI's, the assaults, the attempted

criminal charges with the LAPD, many meetings with organization

personnel, the London operation, the "Armstrong Operation" (or

Sherman-Ingrain Operation), more attempted criminal charges with

the LA DA and the FBI, media campaigns, "Freedom" campaigns. Yet

the documents the organization offers end, but for a few

exceptions, in the spring of 1982. Each of the operations or

attacks is GO province and function. Organization attorneys are

trying to make believe that if the name changed the function

disappeared. An analogy would be the War Department under FDR

becoming the Department of Defense. The functions remained the

same and there was, as in GO activities, continuity until present

time. The B-1 file produced is a joke. The organization is

asking me to believe that after it raised me in importance to

-3-

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6254]

its number one or two enemy, all reports, correspondence, orders,

evaluations, programs and operations concerning me ceased. The

material received as "B-1" is a small fraction of the

documentation in the organization's actual intelligence files on

me. Then there are the PR and legal files.

4. I refer the court to my declaration of April 9,

1986 in which I listed various incidents, operations or

publications which were clearly organization creations and

concerning which the organization had produced no documents. The

facts of that declaration, except for the subsequent receipt of

the partial "B-1" file, are essentially the same as they were

then and I incorporate that declaration by reference herein. At

page 14, no. 21 I described the documents still not produced

concerning the "Armstrong Operation," an organization

intelligence operation which has been running from 1982 up to the

present. The organization is still using the fruits of that

operation, in fact, to make millions from its adherents (see p.

22, no. 6 of the April 1986 declaration). To prevent the

organization from being able to completely sidestep the Court's

various orders regarding production of documents with the sham

that the unproduced documents described in my declaration post-

dated the renaming of the Guardians Office, Ms. Dragojevic

served the organization's attorneys with the request for

production attached hereto as Exhibit [B]. This request lists the

documents specified in my declaration as not produced in non-

compliance with the Court's orders. Request no. 21 asks for the

documents relating to the "Armstrong Operation." The

organization's response, signed by attorney John Peterson, is

-4-

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6255]

attached hereto as Exhibit [C]. Mr. Peterson stated in response to

request no. 21:

"Armstrong Operation" is a characterization

invented by Cross-complainant as no such

"operation" has ever existed. Cross-defendant

has no such documents in its possession, custody

or control.

This is such a big lie it boggles the mind. "Armstrong

Operation" is the organization's term: however the operation's

name is irrelevant. If the organization labelled the operation

"Armstrong Program," "Destroy GA Plan" or " Freakout II," it does

not matter. Mr. Peterson knows what is being referred to because

he was and is an active participant in the operation. He filed

sworn declarations in this case and in many more across the

country, and with several government agencies. He used his

perverse rendition of the operation, in fact in the "Further

Opposition to Motion to Compel Production of Documents" filed

with this Court May 8, 1985. If Mr. Peterson is believed, that

there are no documents concerning an operation over almost 6

years involving dozens of people, incredible expenditures of

money for extra-legal actions, a bevy of PIs, three countries,

illegal videotapes, bugs, a paid-off dirty cop, millions of

"Freedom " tabloids devoted to the operation distributed

internationally, manufactured evidence foisted on the LAPD,

LA DA, Courts and the FBI, and a get-rich-quick scheme involving

millions of dollars internationally, he sends a message back to

his client organization that lies still work and it is still

good strategy to thwart and abuse legal procedures.

-5-

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6256]

5. Attached hereto as Exhibit [D] is a series of daily

reports concerning me from intelligence personnel in the Greater

Los Angeles GO to posts in GO US covering the period from

February 22 to March 18, 1982. This was before the first SP

Declare was issued on me. As can be seen, intelligence daily

reports were created for actions as simple as the stakeout of

Omar Garrison's residence even when nothing was observed. To

say that the "Armstrong Operation" was created with no

documentation, no orders and no funding, and that no reports

were generated over four-plus years is beyond absurd. It should

be noted that each of the individuals holding posts which

received the reports or copies, also therefore possessed

Armstrong documents and files.

6. Attached hereto as Exhibits [E], [F], [G] and [H] are

documents entitled respectively "Juggernaut" Eval, Operation

Freakout, Goodrich Suit Evaluation, and Christo Final Handling

Eval. The Juggernaut document is a broad evaluation and program

to attack Michael Flynn. The number of people involved is shown

by the post distribution list on the first page. Freakout was

an operation to frame a Scientology Critic, Paulette Cooper (PC)

with a fake crime much as the organization has attempted with me

on several occasions. The Goodrich document was written by

Hubbard and is a model for attacking individuals with claims

against the organization (see "Goodrich Eval" under the Policy

section of the Juggernaut Eval). The same perfidious strategy

used by the organization and its attorneys to invade my privacy

cull and miscull my PC folders, and put the culled and misculled

product, further distorted by their sinister minds, before the

-6-

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6257]

Court, is devised and ordered by Hubbard at page 14 of this

document. The Christo Final Handling Eval, which is clarified

by my affidavit of March 8, 1985, also attached as part of

Exhibit [H], concerns in part bringing criminal charges against

Julie Christofferson, her associates and family, on Hubbard's

orders. The organization similarly attempted bringing false

criminal charges against me. Julie Christofferson was in

Scientology for a few months in a fringe franchise when she was

17 years old. Yet the organization in compliance with Hubbard's

orders created this sophisticated program to destroy her,

including use of her auditing session statements against her

(see p. 2, operating target 4 under Libby/Eureka, Montana). It is

unimaginable that the organization has done all it has to me,

operation after operation, yet has no evaluations, programs or

operations files concerning me. The only other possibility is

that the organization and its attorneys have, in anticipation

or violation of the Court's discovery orders, destroyed the

evidence of their operations against me.

7. Mr. Peterson's response regarding a manuscript,

artwork and other materials stolen from the trunk of my car on

November 8, 1984 (see request no. 15 of Exhibits B and C) is:

Cross-defendant has no knowledge of any burglary

of Cross-complainant's trunk. Hence, cross-

defendant has no such documents in its possession

custody or control.

Attached hereto as Exhibit [I] are a letter dated November 9, 1984

from Ms. Dragojevic to Mr. Peterson and his reply dated November

30, 1984. Ms. Dragojevic advises Mr. Peterson of the theft and

-7-

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6258]

makes a demand for return of the materials stolen. He answers

with accusations and threats. His claim now that his client has

no knowledge of the burglary is just not true.

8. Another example of documents clearly withheld by

plaintiff organization is in regards to the program to get the

LA DA to bring criminal charges against me -- ultimately to have

me jailed. This is all part of the "Armstrong Operation." At

p. 23, no. 11 of the April 1986 declaration I showed, from the

mouth of CSC, CSI, RTC and Hubbard attorney Earle C. Cooley, the

existence of such documentation. The organization has produced

none of these documents. A letter from the Office of the LA DA

dated April 25, 1986, attached hereto as Exhibit [J], however,

reveals that Mr. Peterson and organization personnel provided a

mass of documentation, even more than I knew before then existed,

to the DA. Mr. Peterson knows that I know because he got the

DA's letter. To consider that all this was done from no written

orders, programs, evaluations or missions is madness. It should

be noted that the recipients of the DA letter were all GO staff.

Lyman Spurlock's testimony at trial in 1984 that he (as ASI

staff) and others got rid of the 1100 GO staff criminals is

untrue. Ken Hoden was GO staff: in fact he was involved in the

program on Hubbard's orders to bring criminal charges against

Julie Christofferson. Heber Jentzsch was a GO PR staffer for

many years who was used for the organization's frontal PR attacks

on enemies. He continues to perform the same organization

function. David Butterworth is a longtime GO staff member. When

I knew him in the organization he was an aide to Mary Sue Hubbard

in the Controller's Office. John Peterson has been connected to

-8-

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6259]

the GO from the 1970's.

9. The organization has likewise still not produced the

documents specified in connection with the other operations

listed in my April 1986 declaration. I will not restate all

these operations or the relevant documents, however, each

operation is GO territory and each document relating to each

operation fits squarely under the Court's various discovery

orders. I cannot consider that the orders have been complied

with until the documents relating to all operations are received.

There are literally thousands of documents being withheld by the

organization and its attorneys.

10. What the organization also is doing to avoid

exposure and compliance with discovery orders is to strip the

plaintiff "corporation" of its personnel, functions, buildings,

assets and files. When I left the organization, the Church of

Scientology of California (CSC), under Hubbard, was the entire

GO, Sea Organization, and all Scientology above small outer

organizations and franchises, which were even then under CSC/

Hubbard control. Attached hereto as Exhibit [K] are pages from

the deposition of Cynthia Morrow, "managing agent" of CSC, taken

October 29 and 30, 1985 in the case of Church of Scientology of

California v. Jordan, LA Superior Court No. C538 049. Ms.

Morrow testifies that by 1985 CSC had been stripped of all

money-making organizations (service orgs) and was merely an

"Office of Special Affairs." In the Christofferson case in

Portland, Oregon, former Executive Director International,

William Franks testified that in December 1981 CSC had a net

worth of $340 million and $150 million in one Sea Org Reserves

-9-

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6260]

account alone. His testimony is attached hereto as Exhibit [L].

In the case of Wollersheim v. CSC, just tried in LA Superior

Court, the organization submitted a financial statement,

attached hereto as Exhibit [M], claiming a net worth for CSC of

$18,667,947.00. On information and belief, in September CSC

claimed that it had decreased its net worth another $6 million

plus since the May financial statement was prepared, leaving a

net worth of around $12 million. The organization's various

conveyances and corporate machinations, however, should not

shield the organization from liability for its tortious and

criminal acts, and should not provide an escape from non-

compliance with discovery orders. The Court has already ruled

on the alter ego issue in this case, and this reasoning is

applicable to this discovery matter. The people who run CSC

run all of Scientology, and they can produce any document

having anything to do with me now in the possession of any

Scientology unit, organization, corporation or individual.

11. Attached hereto as Exhibit [N] is an organization

policy written by Hubbard entitled "Order Board and Time

Machine." In it Hubbard states as "a major policy:"

"if it is not written, it is not true."

He goes on to set as policy: "Even when one gives a verbal order

it is also written down." There are literally dozens of

organization policies insisting emphatically on the same thing:

written orders, written compliances, written programs, written

projects, written evaluations. Written orders, programs and

missions are "word-cleared,"drilled," and "done in clay" so they

are fully understood. It is impossible with verbal orders or

-10-

   

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 6261]

reports. Even if the organization is hiding its orders, reports

and files on me electronically in its computer system, and even

if under my initials or a code designation, they exist. "If it

isn't written it isn't true," and the insistence on everything

being in writing is hard policy in all Scientology organizations.

Virtually nothing except for body functions, at the Sea Org/GO/

OSA/CSC level is done without written orders and a written

record.

12. The organization's strategy, beyond its direct

attacks aimed at my personal destruction, is to lie and stonewall

to hopefully delay the January 1987 trial, or make it, with

obstructions of all kinds, unbelievably difficult to try the case.

The organization and its attorneys, who accuse me of conspiracy,

are the conspirators in this paranoid and dangerous plan to

thwart legal redress of their victims. The Court can move along

the case and the discovery matters, and the organization's

assault on sanity and justice can be checked by enforcing full

compliance with its various orders, and the intent of the law.

I declare under the penalty of perjury under the laws

of the State of California that the foregoing is true and correct.

Executed this llth day of October, 1986 at Boston,

Massachusetts.

[signed]
Gerald Armstrong

-11-

   

    

Exhibit [A]
B-1 "Time Track" Chronology [.pdf]

Exhibit [B]
Request for Production of Documents 08- 04-1986

Exhibit [C]
Response to Request for Production of Documents 09-02-1986

Exhibit [D]
B-1 Daily Reports [Clerk's Transcript Pages 6262 - 6275]

Exhibit [E]
Juggernaut Eval [.pdf]

Exhibit [F]
Operation Freakout

Exhibit [G]
Goodrich Suit Evaluation [.pdf]

Exhibit [H]
Christo Final Handling Eval [ .pdf]

Exhibit [I]
Letter from Ms. Dragojevic to Mr. Peterson 11-09-1984

Exhibit [J]
Letter from Office of the LA DA 04-25-1986

Exhibit [K]
Cynthia Morrow deposition (excerpt) 10-29-1985, 10-30-1985

Exhibit [L]
Testimony William Franks 12-1981

Exhibit [M]
Scientology's financial statement submitted in Wollersheim v. CSC

Exhibit [N]
HCO PL 1 May 1965 Order Board and Time Machine © 1965 L. Ron Hubbard

   

§   What's New  ||  Search   ||  Legal Archive  ||  Wog Media  ||  Cult Media  ||  CoW ® ||  Writings  ||  Fun  ||  Disclaimer  ||  Contact  §