I, GERALD ARMSTRONG, declare:

(1) In the case of Julie Christofferson-Titchbourne v. Church of Scientology of California, et al., Multnomah County, Oregon, Circuit Court No. 7704-05184, currently being tried in Portland, Oregon, defendant organization was ordered to produce my B-1 files. B-1 is Bureau One, the Intelligence Bureau of the Guardian’s Office.

(2) Although the names B-1 and Guardian’s office have been changed, the same intelligence functions are still performed by Scientology connected organizations. I was present in court during the Christofferson trial, when Howard Gutfeld, a Scientology representative, testified that B-1, intelligence files and private investigator reports are now maintained in the office of Special Affairs, a branch of Scientology.

(3) Defendant organization in Christofferson produced approximately five inches of materials from my B-1 files. Many of the intelligence reports or operations programs referenced in the B-1 materials produced, have been deleted by defendant organization. Nevertheless, the materials which were produced are completely relevant in the instant case. The materials produced are all internal Scientology correspondence or programs, and there is no correspondence to or from attorneys.

[page break]

(4) There are numerous references to my preclear (pc) files in the produced B-1 materials, and there are entries in the B-1 time track, the chronology that forms part of the B-1 materials, which show unequivocally that Scientology intelligence personnel had my pc files after I left the organization, and excerpted data for intelligence use. One such entry uses the words “in session” as source of an account of a sexual encounter I had with a woman. “In session” means that the information came from the auditor’sreports in an “auditing session.”

(5) My pc folders were used as well in the operation by Scientology/Hubbard against me which resulted in the illegal videotaping of me in a series of conversations with individuals who represented to me that they sought to reform the organization and correct its abuses. There are statements on the videotapes which substantiate the fact that my pc folders were used as a lure to entrap me.

(6) Just after the trial in the defense part of the instant case and just prior to my going to London, England to testify in a child custody case, I received a call from someone whom I later confirmed was “Joey,” the intelligence operative videotaped along with me in the November 7 and 9, 1984 meetings. In the telephone call, Joey said that my pc folders were being moved and I would be able to get them if I wanted. He said that my folders would be in a certain place the next night where I would be able to pick them up.

Page 2 - DECLARATION OF GERALD ARMSTRONG

(7) In another November, 1984 meeting with Mike Rinder, another Scientology operative, which meeting was also surreptitiously videotaped, my pc folders were also discussed. Rinder stated that (following the Armstrong trial) my folders were moved from Clearwater. This was probably a lie, since the whole operation against me was based on lies by the organization, but it did show Rinder’s knowledge of the use of my pc folders in the operation.

(8) The idea to use my pc folders to entrap me arose from a ” debrief” by my former wife, Terri Gamboa, of a meeting we had in March, 1984 just prior to the Armstrong trial. This ” debrief,” attached hereto as  attachment [A], was recently produced by Scientology as part of my B-1 files and was admitted into evidence in the Christofferson trial. The “briefing” and all other programs and documentation which arose from this “debrief,” have not been produced.

(9) Regarding my pc folders, Mrs. Gamboa states in Attachment A, page 4, paragraphs 6 and 7:

“An important point for him was getting his pc folders back as he feels that that’s the solution

Page 3 - DECLARATION OF GERALD ARMSTRONG

to his future sanity. He brought this up several times.

A line has been established with him and possibly this can be built up from here and used again in the future. He is desperate and he has no way out at this point.”

Terri Gamboa was then working for Author Services, Inc., yet the ” debrief” was in Scientology intelligence files.

(10) There is no doubt that Scientology/Hubbard or their connected corporations have used my pc folders, and used the information and the folders themselves to entrap, intimidate and destroy me. The folders and contents are mine and these organizations do not have the remotest right to them.

Sworn under the pains and penalties of perjury this 7th day of May, 1985.

Executed at Portland, Oregon.

Page 4 - DECLARATION OF GERALD ARMSTRONG

Page 4 - DECLARATION OF GERALD ARMSTRONG