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DECLARATION OF GERALD ARMSTRONG

 

I, Gerald Armstrong, declare:

 

1. I am making this declaration in response to the

allegations made in the reply of cross-defendant Scientology

organization in support of its motion to initiate an investigation

of alleged violations of temporary restraining order re contempt.

2. Although I have never met LaVenda Dukoff and have only

spoken to her on the one occasion she is refering to at paragraph

19 of her affidavit of June 9, 1986, I have known about her and

her involvement and litigation with the organization for several

years. I had written a couple of affidavits for her on issues

about which I had factual knowledge which arose in her litigation.

Ms. Dukoff's case had settled before I started working for Michael

Flynn in September 1985, so her name rarely came up in office

conversations. The main impression I formed about her up to the

time of her call was that she was a victim of Scientology and

unstable. I became aware last fall, when the organization filed

the original motion to initiate an investigation, of its claim,

which it based on one of the many affidavits Paulette Cooper

signed for it on March 4, 1985, that in the fall of 1982 Ms.

Dukoff had telephoned Ms. Cooper and said "Mike (Flynn) showed me

the Armstrong documents that were under seal." I was aware of

the organization's use of its victims and purchased false

testimony in its operations (see declarations of Paulette Cooper,

Joseph Flanagan, and Michael Flynn of September 30, 1985 re

Ala Fadili Al Tamimi and other paid criminals) and I speculated

 

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when I saw the organization's motion to initiate an investigation

that Ms. Dukoff might herself be involved in a Scientology

operation. I was, therefore, very alert and very careful when

she announced herself on the telephone around the beginning of

June.

3. Ms. Dukoff's call came in on an afternoon when the

office was normally closed, because there were only two people

there, myself and attorney Robert Joyce. Michael Flynn had left

for home only moments before, and following my conversation with

Ms. Dukoff I reached him on his car phone and related the details.

The phone rang, I answered, and a woman asked for Mr. Flynn. I

said he was not in and asked if I could take a message. She gave

her name and I gave mine. She immediately announced that she had

sealed documents from my case and she was going to take them to

the press to get Mike Flynn. As soon as she made the threat,

I put her on hold, asked Mr. Joyce to come into my office to hear

the call, then switched her onto the speaker phone when I took her

off hold. Mr. Joyce was therefore present and heard all of what

Ms. Dukoff and I said, except for the first sentence noted above,

a threat she repeated a number of times throughout our

conversation.

4. Ms. Dukoff states that she "described some of these

documents" to me, documents she earlier states at paragraph 18

Mr. Flynn said were under seal and for which he or she "could go

to jail." In our conversation, she referred to the documents she

claimed to possess as "Armstrong documents" or "sealed documents."

She did describe, at my request, two or three of these documents,

but very sketchily and, even after some questioning by me, she

 

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could not describe any of her documents with enough specificity

for me to identify them or any as "Armstrong documents"; i.e.

any of those documents I obtained from Omar Garrison and sent to

my attorneys in 1982, and subsequently delivered to the Clerk

of the Los Angeles Superior Court pursuant to the Temporary

Restraining Order issued August 24, 1982. The only document Ms.

Dukoff was able to describe at all intelligently was a "will", the

original of which she said she copied, but she did not know its

date or content. I even told Ms. Dukoff that there was no way

from what she was telling me that I could know that she even had

sealed documents.

5. Ms. Dukoff's statement that I told her "that exposure

of the dissemination of these documents would destroy (my) court

case against the Church of Scientology" is incorrect. The only

thing I said to her repeated threats to go to the press with

"sealed documents" or cause Mr. Flynn or me trouble, was "you 've

got to do what you've got to do." I never considered, nor do I

consider, that Ms. Dukoff's going to the press, or Scientology,

or anyone else with sealed documents, or forged documents, or

any other kind of documents, would destroy my court case. I

would not state such a thing, not only because I was aware from

the outset that the whole Dukoff document affair was likely a

Scientology operation, but because in truth I do not feel that

way. It was Ms. Dukoff who said that her going to the press with

sealed documents would hurt me.

6. Ms. Dukoff's statement that I "obviously recognized

these documents as (I) became very upset" is a false conclusion

based on falsehoods. I did not recognize any of the Dukoff

 

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documents and did not become upset. I remained calm, did not

raise my voice, and said nothing which could be interpreted by

any rational person as becoming "very upset." I was, however,

saddened by Ms. Dukoff's call, by her attack on Mr. Flynn, who

she said had "fucked" her and whom she was now "going to fuck, "

and by the fact the call evidenced another Scientology operation.

Following the call I was acutely depressed. Virtually all of

Ms. Dukoff's recitation of our conversation is false.

Executed this 2nd day of August, 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.

[signed] G. Armstrong
Gerald Armstrong

 

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See also:
Michael Flynn Declaration 07-31- 1986
Judge Breckenridge Minute Order 08-18- 1986
See how the cult is continuing to use Van Schaick's perjurious declaration in its CLameleon Intel Op

 

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