§  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

 

I, GERALD ARMSTRONG, declare and state that:

1. I am the defendant and cross-complainant in the

case of Church of Scientology of California vs. Gerald Armstrong,

Los Angeles Superior Court No. C420153. I was a member of

Scientology from 1969 to 1981 and have been involved in

litigation with various Scientology entities, hereinafter

referred to as "the organization", since 1982. I have testified

approximately 47 days in trials or depositions in at least 10

cases against Scientology. I am very knowledgeable in

Scientology litigation and operations, and am qualified to render

the opinion in Paragraph 7 below.

2. In 1985 and throughout 1986, I worked as a

paralegal in the law firm of Flynn, Joyce and Sheridan in Boston,

Massachusetts. I worked on all the organization-related

litigation handled by the firm during that period. Michael Flynn

was the prime mover in much of the organization-related

litigation throughout the United States until December 1986 when

he settled all the cases in which he was involved. I was

represented in Armstrong by Flynn, Joyce and Sheridan and the law

firm of Contos and Bunch in Woodland Hills, California until the

settlement.

3. In a declaration I executed December 25, 1990,

which I filed in the California Court of Appeal in the

organization's appeal (Civ. No. B038975) from a Superior Court

ruling unsealing the Armstrong court file, which had been sealed

in December, 1986, I detailed the circumstances of and my

involvement in the settlement. In that declaration, I waived the

attorney-client privilege between Mr. Flynn and me only as to our

 

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

 

conversations concerning the settlement, and I reiterate that

waiver at this time, and extend it to include my other attorneys.

4. During the settlement negotiations and thereafter,

I learned from Mr. Flynn, and two other attorneys in both firms

which represented me in Armstrong, that all the attorneys who had

been involved in the organization-related litigation had agreed,

as part of the settlement, to not represent or assist anyone in

any future litigation against the organization.

5. Each of the law firms involved was also required,

as part of the settlement, to turn over to the organization its

Scientology-related documentary evidence, as was each of the

litigants. Each of the litigants, moreover, was required, as

part of the settlement, to not assist any aggrieved party in

future litigation against the organization, and to avoid service

of process in such litigation. These conditions are stated in

the settlement agreement I signed in December 1986, a copy of

which is marked and exhibited herewith as Exhibit "1".

6. Since the settlement, the organization's attorneys

have threatened me on six occasions that I would be sued if I

violated the settlement's restrictions. The organization

meanwhile has itself violated the letter and spirit of the

settlement regarding me on numerous occasions. I have detailed

these instances in my December 25, 1990 declaration and a

declaration I executed on March 15, 1990 which was also filed in

the above-referenced appeal.

7. The effects of the December 1986 settlement

agreements in the legal community and on future individuals

aggrieved by the organization are obvious. Potential attorneys,

 

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

 

knowing or learning that they would be denied the documentary

evidence which had previously been available, denied assistance

from the key witnesses against the organization, and denied

assistance from the most knowledgeable attorneys in the world in

this field of litigation would be more than reluctant to accept

representation of aggrieved individuals. Add to that, the

general knowledge in the legal community of the harassive and

threatening practices of the organization toward adverse

attorneys, and the fact that well respected attorneys such as Mr.

Flynn had agreed to an unethical or illegal settlement to escape

the litigation, and it is no surprise that this country's

attorneys avoid representing the organization's many victims.

The victims are effectively cut off from communication with

witnesses and access to evidence, and their ability to obtain any

legal representation denied.

I declare under the penalty of perjury under the laws of the

United States and the State of California that the foregoing is

true and correct and based on my personal knowledge, except those

matters stated on information and belief, and as to those

matters, I am informed and believe them to be true.

Executed this 16th day of July, 1991, at Los Angeles,

California.

 

[signed] G. Armstrong

GERALD ARMSTRONG

 

 

3

Image of signature page

 

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