Gerry Armstrong--

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DECLARATION OF LYNN R. FARNY

I, Lynn R. Farny, do declare:

1. I am over 18 years of age and make this declaration of

my own personal knowledge and for those matters stated upon

information and belief, I believe them to be true and accurate.

If called as a witness to testify as to the matters herein, I

could and would do so competently.

2. I am corporate Secretary of the Church of Scientology

International ("CSI"), a California religious corporation.

3. I have reviewed the photographs which are attached to

the declarations of Sam Brown and Thorn Smith, Exhibits D

and I to the Supplemental Memorandum in Support of Motion to

Dismiss the Complaint. I recognize the individual in the

photographs attached to the Smith declaration as John Koresko

and the individual in the photographs attached to the Brown

declaration as Gerald Armstrong.

4. I am well familiar with Gerald Armstrong, as I have

worked in the legal department of CSI since 1984, and prior to

that in the legal department of Church of Scientology of

California ("CSC"). I have actively followed the events

occurring during that time in lawsuit against Gerald Armstrong

by CSC regarding his theft of private documents belonging to

the Founder of the Scientology religion.

5. I am also well familiar with John Koresko, who was

office manager and later a paralegal for Joseph A. Yanny,

CSI's former attorney, during the time that Yanny represented

///

CSI and afterwards, when CSI and CSC sued Yanny for his

breaches of fiduciary duties.

6. 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. 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). 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

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

-2-

to allege it.

I declare under penalty of perjury under the laws of the

State of California that the foregoing is true and correct.

Executed in Los Angeles, California the 26th day of August

1991.

[signed] Lynn R. Farny
LYNN R. FARNY

-3-

Image

See also Armstrong Declarations:
02-22-1994
02-20-1994

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