EXHIBIT B

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

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DECLARATION OF GERALD ARMSTRONG

I, GERALD ARMSTRONG, being duly sworn, hereby state and declare as follows:

1) In September of 1980, I was staff member of L. Ron Hubbard, Director of the Church of Scientology of California. My superior was Laurel Sullivan, and during that time I worked with her on two projects, an authorized biography of L. Ron Hubbard and the Mission Coporate Category Sort Out (MCCS). Laurel and I were involved in MCCS when the project was initiated, before the Church sought any legal advice and before the September 1980 meetings occurred, which are described in my first affidavit.

2) The MCCS Mission was initiated from orders we received from L. Ron Hubbard. Hubbard ordered us to figure out a way in which his control of the Church of Scientology could be hidden, yet he would still maintain de facto control. This was done to hide Hubbard's control of the Church of Scientology and the numerous benefits he inured from it. If Hubbard's control was known, he would become involved in the litigation confronting the Church. His inurement of Church benefits would also affect litigation with the Internal Revenue Service which was then being fought concerning the Church of Scientology's tax exempt status.

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The whole purpose of the MCCS Mission was to defraud the federal government, litigants against the Church, and the Courts into believing Hubbard had no involvement with the Church of Scientology, and therefore was protected from litigation. The corporate restructuring of the Church was to be performed to meet this objective. All of the activities performed by anyone involved in the MCCS Mission, including the attorneys, were done to achieve this fraudulent end.

3) The two meetings which are described in my prior affidavit were part of a series of meetings, whose purpose was to obtain the fraudulent and illegal objective of the MCCS Mission.

4) Barbara De Celle was also involved in the MCCS Mission. She borrowed the tape recorder and the tapes used to record the meetings described in my prior affidavits from me. Several months later in the summer or fall of 1981, she gave me the tapes and told me they belonged to the biography project. At that time, I was working exclusively as a research assistant to Omar Garrison, the author hired to write the biography of Hubbard. De Celle and everyone else who was on staff knew that any materials that were given to me for the biography would be turned over to Garrison. Garrison had no connection with MCCS and was not even a Scientologist. After Barbara De Celle gave me the

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tapes, I turned them over to Garrison.

5) Barbara De Celle voluntarily gave me the tapes of her own volition. I never asked for them, nor did I surreptitiously take them from her desk. She gave them to me one day when I happened to pass by her disk.

6) I have described these tapes in other affidavits which I have signed. One such affidavit was executed in the summer of 1982 for use in the case of Burden v. Church of Scientology of California, Middle District of Florida, C.A.

No. 80-501-Civ-T-K. To my knowledge, my description of those meetings, which is identical to the description contained in the affidavit I filed in this case is still part of the public record of the Burden case, and has never been struck.

Signed this 31st day of December, 1984 under the pains and penalties of perjury.