DECLARATION OF MICHAEL J. FLYNN

I, MICHAEL J. FLYNN, declare as follows:

1. I am an attorney licensed to practice before all of the

Courts in the State of Massachusetts and am associate counsel,

together with the law offices of Contos & Bunch, counsel for

defendant-counterclaimant Gerald Armstrong in this action. If

called upon to do so, I would testify competently as to the

matters set forth herein.

2. Since the inception of my representation of former

members and victims of the Church of Scientology, in approximately

July, 1979, I have been continuously harassed by L. Ron Hubbard,

Mary Sue Hubbard, and the Church of Scientology, its agents and

representatives. See Declaration of Michael J. Flynn with

accompanying exhibits on file in this action, Docket No. .

3. Following the trial of the issues set forth in the

plaintiff's Complaint in this action, which trial ended on or

about June 8, 1984, the Church of Scientology its agents and

representatives, specifically attorney John Peterson and Eugene

Ingram, a private investigator working for L. Ron Hubbard and

John Peterson (see Exhibit 1 attached hereto) initiated a vicious,

false, and prolonged campaign to "frame" me, to destroy my

reputation, and to countermand the effects of the findings of

fact and conclusions of law made by this Court in its Order dated

June 20, 1984, in this action. In connection with these efforts

spearheaded by Ingram and attorney Peterson, Ingram and

church officials toured virtually every major city in the United

States conducting press conferences in which they claimed that I

had conspired with an individual named Ala Fadili Al Tamami to

forge a $2,000,000 check of L. Ron Hubbard. See attached press

releases, news articles and publications issued by the Church of

Scientology attached hereto as Exhibit B. Ingram, Peterson and

others also claimed, inter alia, that I was a member of organized

crime, that I had threatened to break peoples' legs, and that I

was a participant in various types of fraud and criminal activity.

Needless to say, the allegations of Ingram and Peterson are absurd.

See Declaration of Michael J. Flynn attached hereto as Exhibit 2.

4. In connection with the foregoing scheme, Ingram, his

agents and representatives, including Richard Mueller, Andrew

Palermo, Richard Hamilton, and others conducted unlawful, covert,

and intense surveillance of myself and my client Gerald Armstrong.

Surveillance of myself has included being followed virtually

everywhere I have gone in the United States by sometimes as

many as three cars, in continual contact with clients, relatives,

friends, and acquaintances, most of whom have been told that I

was the subject of a "federal investigation".

5. For the past four years I have suspected that my tele-

phone communications were being intercepted and recorded by the

Church of Scientology, its agents and representatives, including

Eugene Ingram. On Thursday, April 4, 1985, I learned of some

evidence to support this suspicion. During the course of the

trial testimony of Gerald Armstrong in the case of Titchbourne v.

Church of Scientology, Multnomah County Circuit Court No. ,

counsel for the Church of Scientology sought to introduce into

evidence a video tape and audio recording of Gerald Armstrong

taken without his consent. The trial Judge, Londers, denied

introduction of video tape on the grounds that it was made