Declaration of John G. Peterson

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Related Litigation


INTERNATIONAL, a corporation
corporation, and SCIENTOLOGY



OF SCIENTOLOGY, a corporation,
individual; and AVRA HONEY-SMITH,
an individual,


NO. 85-0412T


I, JOHN G. PETERSON, declare and say:

l. I am an attorney at law, duly licensed and authorized to practice before all the Courts of the State of California and the United States District Court of the Central District of California.

2. I represent the Church of Scientology of California as general counsel on civil litigation matters and submit this declaration in support of Plaintiffs' Motion for a Protective Order regarding Defendants' notice of deposition of L. Ron Hubbard as an officer, director or managing agent of the Plaintiffs in the above-entitled action. In my capacity as general counsel to the Church of Scientology of California, I am familiar with the corporate structure of the California Church as well as the corporate structure of all Churches of Scientology in the United States. I submit this


declaration for the purpose of demonstrating that Mr. Hubbard is not, and was not at the time of the Defendants' notice of deposition director or managing agent of any Church or mission of Scientology.

3. Each Church of Scientology is a separate and distinct legal entity with its own articles of incorporation and bylaws which determine its own affairs through its duly elected Board of Directors and officers to exercise sole legal authority over these corporations. The Churches, of course, share the same religious creed and beliefs based upon Scientology Scripture created by the Founder of the Scientology religion, L. Ron Hubbard, and are affiliated in the ecclesiastical sense much like other religious institutions. However, in matters outside the religious sphere, these Churches exercise their own independent and distinct legal authority in running the day to day affairs of the corporation.

4. Mr. Hubbard is not an officer, director or managing agent of any Church of Scientology, including the Plaintiffs in this action. Mr. Hubbard possesses no legal authority over these Churches and is not legally vested with any authority or power to act for or on behalf of the Churches of Scientology concerning any matter. Mr. Hubbard cannot bind any Church contractually nor in any other way legally obligate any Church of Scientology. Mr. Hubbard also does not have any managerial duties whatsoever in connection with any of the Churches of Scientology. He is not a shareholder of any church corporation as all Churches of Scientology are non-profit, religious organizations. He possesses no signatory power over any Church corporation or church financial accounts and is not in any way authorized to obligate the Churches financially. Likewise, the


Churches are not authorized to obligate Mr. Hubbard in any manner. Mr. Hubbard also does not possess any legal authority to hire or fire any individuals from any position within the Churches of Scientology. In short, there is no corporate action or function which Mr. Hubbard is empowered to perform.

5. Neither I, nor any Church of Scientology possess any means to compel the presence of Mr. Hubbard at a deposition or to perform any function on behalf of the Churches. If required to do so, the Churches would not be able to produce L. Ron Hubbard for a deposition. Accordingly, Mr. Hubbard cannot be depended upon to carry out the direction by the Church to give testimony at a deposition.

6. I possess no knowledge of the current whereabouts of Mr. Hubbard and know of no one else who possesses such knowledge. Furthermore, I have made inquiries in order to determine whether any Church has communicated with Mr. Hubbard either directly or through intermediaries and I have determined that no such communications have taken place since well before defendant first noticed Mr. Hubbard's deposition in this action.

7. In my capacity as general counsel I am familiar with all litigation matters concerning the Church of Scientology of California.

8. All of the declarations submitted by Defendants can be shown to have been given by perjurers, extortionists, unscrupulous and vindictive individuals, who have been removed from their positions within the Church of Scientology. Their testimony is false. The voluminous documents showing these facts will be provided for the Court's convenience, if it so requests.


9. Defendants in this action have submitted the Declarations of Laurel Sullivan, Kima Douglas, Gerald Armstrong, Warren Friske, John Nelson Diana Reisdorf-Voegeding and William Franks. These Declarations, on their face, establish that Laurel Sullivan ceased her involvement with CSC in 1981, Kima Douglas on January 17, 1980, Gerald Armstrong in December, 1981, William Friske in 1982, William Franks in 1981 and John Nelson in December, 1982.

10. I am personally familiar with the factual record from other cases in which it has been made clear that the declarants who have supplied statements used by the Defendants in this action have lied and have contradicted themselves under oath in regard to significant points of their statements.

Laurel Sullivan

ll. In her declaration of August 20, 1984 submitted here by defendants, Laurel Sullivan states that a major aspect of her responsibilities through 1981 "was to promote the false impression that Mr. Hubbard was not in control of the Church of Scientology" and she alleges instances through 1981 when L. Ron Hubbard purportedly exercised control over the Church. However, under oath during cross-examination in the trial of Julie Christofferson-Titchbourne v. Church of Scientology of California, et al. she attested that Mr. Hubbard went "off the lines" (no longer in communication) of the Church in March, 1980. (See Christofferson trial transcript, page 6946, Exhibit 2.) Several years earlier, in a deposition in the case of Times Publishing Co., et al. v. Church of Scientology, et al., Sullivan (then, Laurel Watson) stated:


"I do not know his opinions (L. Ron Hubbard's) on this suit, or any other suit, and I know him to be completely uninvolved in that type of thing. As far as he is concerned, Scientology can handle their own business and affairs and whatever. He personally prefers to be in a much more creative frame of mind about writing or photography or music, and has preferred to pretty much stay into the arts since he resigned. He has done some exploring, that sort of thing . . . . He isn't a spokesman for the Church any longer. He is a spokesman for himself." (Attached as Exhibit 3.)

12. Laurel Sullivan was Hubbard's public relations officer until July, 1981 (See transcript of CSC ys. Armstrong, p. 3027, Exhibit 4), but had not spoken to Hubbard since October, 1979 (See Deposition of Sullivan, p. 52, Exhibit 5), and received no written communications from him after May, 1981 (See transcript of CSC vs. Armstrong, p. 3124, Exhibit 6). Moreover, the communications Sullivan received after February, 1980 had nothing to do with the "management" of any Scientology organizations. Even prior to October, 1979, Ms. Sullivan often did not see Hubbard at all for months at a time, and heard from him only infrequently (See Deposition of Sullivan, pp. 52-53, Exhibit 7). Since November, 1981, Sullivan has had no relationship with any Scientology organization (Deposition of Sullivan, pp. 35-36, Exhibit 8).

Diana Reisdorf-Voegeding

13. Another of Defendants' declarants, Diane Reisdorf-Voegeding, is also an embittered ex-Scientologist who was in effect ex-communicated from the Church. The true reason for Reisdorf-Voegeding's removal from the Church was her opposition to the actions taken by current Church management to bring under control and fully into accord with Church policies the now-abolished Guardian's Office.


This -- rather than the wild story given in her Declaration is the real reason for Reisdorf's dismissal from her management position. On July 19, 1981 the Commodore's Messenger Organization, and not L. Ron Hubbard, put out a communication explaining the reason for Reisdorf-Voegeding's removal, which is attached as Exhibit 9.

14. In her declaration, Reisdorf-Voegeding states, in an effort to gain credibility for the remainder of her statement, that from 1972 through January of 1982 she "had almost daily personal contact with L. Ron Hubbard."

Yet in an earlier deposition of Reisdorf-Voegeding, she stated:

Q. How frequently would you say you saw him (L. Ron Hubbard] during that period of time?

A: We were doing management. And I used to go over the stats. Not all the time, but many of them. So from April '79 to January '80, maybe a couple of times a month I think I saw him face to face. But I had - -

Q: We're focusing here on daily personal contact.

A: Okay. That's it, then.

Q: After January of 1980, I take it you had no personal contact with him, is that correct?

A: On a face-to-face basis?

Q: That's correct.

A: That's correct.

(See attached Exhibit 10.)

l5. A further example of the complete lack of foundation of the stories spun by Ms. Reisdorf in her accusation in her Declaration regarding the alleged involvement of L. Ron Hubbard in illegal acts purportedly conducted by the Guardian's Office of the Church is her


testimony in deposition. During examination under oath, she admitted that she was basing her allegations upon fragmentary conversations which she only partially overheard and in which she did not participate and to which she did not pay attention. She also admitted that she was unable to recall the content of these conversations. Specifically, in deposition she stated:

Q: Am I correct in understanding that, according to you, L. Ron Hubbard discussed the fact that apparently illegal acts occcurred? Is that a correct statement?

A: Yes.

Q: He also stated words to the effect, to you and the other messengers there, that he had not been knowledgeable of these things; is that correct?

A: Yes.

* * *

Q: Are you stating that you have personal knowledge that L. Ron Hubbard committed criminal acts? . . .

A: What I'm stating is that, during the time I knew him, he was involved with directing Mary Sue and the Guardian's Office; and that included knowledge of, approval of, or at least the knowledge of things from Snow White, to the Pauletter Cooper, to the actions that were occurring at UCE when we were in Florida regarding the mayor.

What exactly he stated, his exact words, I could not reproduce. Mary Sue was -- I mean, it's based on my conclusions. I was -- I mean, it's based on my conclusions. I was -- the data I have, based on my knowledge, was that Mary Sue would go into his office, for instance, at UCE in Clearwater -- in Dunedin. And when we were having flaps there, we'd go over it with him; she would take notes; he would give orders. I do not remember all the orders. I probably couldn't even remember any of them. I wasn't interested in that sort of thing at the time, nor am I particularly now.

And she would make notes and report back to him. That to me was a conclusion that he was giving her orders surrounding that situation.

Q: Were you present in the office during this time?


A: In and out.

Q: And you were not paying attention to exactly what was going on?

A: No.One of my duties was, for instance, get him things, like a cigarette, not listening to the words going back and forth at that time.

Q: What you're saying is: Based upon bits and snatches of conversations you would hear and observing the fact that the two were in communicaiton, you drew the conclusion that he was directing some of these criminal acts; is that an accurate statement?

A: You cut out part of what I said; but yes, that's partly what I said.

(See attached Exhibit 10.)

Kima Douglas

15. The Declaration of Kima Douglas is immaterial and replete with falsehoods. Mr. Douglas asserts no first hand knowledge of any information relevant to the managing agent issue. Indeed, the sum of the Douglas Declaration is that in the mid-1970's Mr. Hubbard received some sort of occasional communications on Church matters. This is not at issue, is not contested and is not relevant in the least to the issues immediately before this Court.

16. I was CSC's counsel in the case of Julie Christofferson-Titchbourne v. Church of Scientology of California et al. ("Christofferson") in the Oregon Circuit Court, County of Multnomah, case #A7704-05184. In that capacity, I was present during ongoing trial testimony given by various witnesses in that case and/or have reviewed the official transcript of proceedings setting forth trial testimony therein.

17. During that trial, sworn testimony of Gerald Armstrong ("Armstrong") and Laurel Sullivan ("Sullivan"), (both are declarants


here), revealed that both are disaffected Scientologists. Their testimony regarding L. Ron Hubbard's status and relationship to CSC, was either deliberately false or so motivated by self-interest and hostility to Plaintiff as to be completely misleading and fraudulent.

Gerald Armstrong

18. Defendants have submitted here an affidavit from Gerald Armstrong executed on September 6, 1984 in support of their opposition. Armstrong subsequently testified for the Church in Christofferson over the course of eleven days, ending April 16, 1985.

19. During the course of Armstrong's testimony, various matters were revealed which cast serious doubt on the credibility of his representation. Through testimony, video tape materials, and other documents, it was revealed that Armstrong's eagerness to cause harm to the Churches of Scientology included his willingness to lie under oath as well as his ready participation in a surreptitious scheme to destroy the religion.

20. Armstrong's September 6, 1984 declaration submitted here claims personal knowledge regarding L. Ron Hubbard's alleged control of the Church. His recent Christofferson testimony, however, completely contradicts that presentation. There he testified that "L. Ron Hubbard could have been dead in 1983, maybe that's the current information. I have no way of knowing that." This new testimony clearly shows that testimony given in Armstrong's own court case upon which his affidavit submitted to this Court was based, was clearly false and that he had no idea whether L. Ron Hubbard was managing or controlling the Church. Indeed, Armstrong's Christofferson testimony discloses that he did not even know if Mr. Hubbard was dead or alive.


21. In a spontaneous conversation recorded on the video tape and admitted into evidence in Christofferson, Armstrong is clearly shown to have no knowledge whatsoever as to who is running the Church. The following excerpt from the video tape transcript shows that Armstrong had no knowledge of who was controlling the Church or who its managing agent was in 1984 or 1985:

(Note: G is Gerry Armstrong, M is Mike Rinder, J is Joey)

G: It can be done during the chaos of whatever RTC, ASI's got going. Who runs the organization right now?

M: Which organization?

G: All of it. Who runs it?

M: Well, it gets run through CMO int.

G: And who are those people?

M: Well, you know, probable the same guys as when you were around.

G: A lot of them are gone.

M: Yeah, quite a number of them are.

[Transcript of video recording, page 6 Nov. 17th, 1984 See Exhibit 11]

This same point was restated in another section of the transcript, but is too obscene to be reprinted here. [See Transcript of video recording, page 32 Nov. 17, 1984 See Exhibit 11]

G: Let's talk to these guys [government agencies], great, I think that they would want to talk in person because they're searching for understanding about it (C of S) with current information. Obviously, the information they have, unless they got ahold of some defectors is not very current. You know, 1982 is really the most current information, I believe of anyone they're talking to that I know of.

[Transcript of video recording, page 25 Nov. 7, 1984 See Exhibit 12]


G: Well, who is ASI? Who are these people? Give me an Org Board. Tell me who the opposition is, who knows that. Where does Marc Yager fit in all this, you know, what is the actual line of control, who is in charge. Cause someone is. All right. You know, the people who are talking about this suit were they in a position to be dealing with the suit, or were they just being told something by someone else who was just hyping them? Who knows? Or maybe it is a weak suit. I think that everything that has happened so far of a long range effect has hurt the organization. Oh, they win with the Bandaid philosophy, but in the long run I think they're going down to take a bath. Anyhow . . . we'll push on.

[Transcript of video recording, page 6 Nov. 9, 1984 See Exhibit 13]

G: You know, whoever in their wisdom is running this thing is doing one f_____ botched job, which is another why, you know you guys would be smart to move in.'

[Transcript of video recording, page 24 Nov. 17, 1984 See Exhibit ll]

22. Mr. Armstrong's testimony and the Christofferson evidence indicate that numerous anti-Church entities were directing and encouraging Armstrong to function essentially as a covert intelligence operative who would:

A. steal documents from the Church to serve as models for forgeries;

B. plot the forgery or false incriminating evidence in Church files;

C. orchestrate a coup in which anti-Church entities would wrest control of the Church of Scientology from its lawful management;

D. steal attorney-client privileged communications consisting of legal strategies;

E. conspire to suborn perjury in order to keep this massive sordid criminal conspiracy under cover;

F. implement a bizarre plot to entrap and destroy the reputation of a senior Scientologist by means of sexual seduction and blackmail.

23. This evidence came to light through the actions of an


attorney and private investigator working in a police authorized investigation. Armstrong was video taped, with recording, as he met with "Joey", a Church of Scientology staff member whom Armstrong believed to be a disaffected member of a group known as the "Loyalists" working within the Church to covertly take over current management. Armstrong detailed his plans for covertly and illegally attacking the Church of Scientology and L. Ron Hubbard, and his efforts to carry out defense attorney Flynn's desire to get an inside source within the Church. A specific conspiracy evolved from Armstrong's activities to steal documents from the Church, thereby obtaining models from which to make forgeries to be planted in Church files. This scheme is graphically disclosed in the video tape 'excerpt annexed hereto as Exhibit 14 and made a part hereof. In the course of his discussions with "Joey", Armstrong bragged that he could "create documents with relative ease."

24. Armstrong's plan to forge documents and plant them in Church files is revealed in the video tapes. This plan was intended to falsely implicate L. Ron Hubbard and Church leaders in non-existent acts. Annexed hereto as Exhibit 15 and made a part hereof are video tape excerpts disclosing Armstrong's proposals for carrying out these objectives. There, he brags how he can "type those goddam things [Church of Scientology directives] and make them look exactly the same," so that "you would not be able to tell the difference." In pursuit of this plan, Armstrong requested that Joey obtain for him original copies of materials "which could be from Hubbard."

25. Armstrong also freely discussed his and other's efforts to orchestrate a coup within the Church. This scheme would have


replaced those individuals currently in control by getting a group within the Church to file a lawsuit designed to obtain a receivership on all properties and assets based on phony allegations -- with no factual support other than forged documents planted in Church files -- and having the newly installed junta immediately settle all outstanding litigation, including Armstrong's $60,000,000.00 claim:

G: I don't know if it makes sense to you to sort of divide up the organization and, uh, go after people on that basis. Just so that you now, "Shit, we have this group covered," and then divide it up structurally so that you have all the various key points which have to be covered. I think that you guys will be able to take over and then use operating income to continue the battle. And that way you can secure the buildings, take it over, and I think that it's going to take that kind of thing. . .

[Transcript of video recording, page 22 Nov. 7, 1984 See Exhibit 12]

G: You know, it could just, it could just be done. The whole. . .you know. . .take. . .if you guy's concentrated only on the CSC. . .on the blue building. And divide the damn thing up and just, you know, the day that the thing happens. You know, the day that you file your complaint, then just call everyone and say that there's a meeting.

[Transcript of video recording, page 5 Nov. 17, 1984 See Exhibit 11]

G: Well, there are hundreds of lawsuits; that's standardly what lawsuits are, you know, a lotta times a. . .lawsuits have that form. It is simply a disagreement over who has control of corporate funds. That is, that is simply the issue. They don't allege that there was any criminal misconduct or illegal use of the funds or anything.

M: But this is alleging that there's criminal misconduct.

G: That's right and the reason for that is because with that, if you can get any of those things, then, then the court can act immediately to freeze the accounts.

[Transcript of video recording, page 18 Nov. 17, 1984 See Exhibit 11]


26. Armstrong's activities also included efforts to steal attorney-client privileged Church communications in an attempt to "penetrate“ the Church's legal area and gain access to the Church's strategy and plans involving its litigation.

27. To prevent any disclosure of other entity's activities in the extensive conspiracy against CSC and other Scientology Churches, Armstrong revealed that he would even commit or suborn perjury. Thus, he announced that he would "never admit that anything comes from Michael [Flynn], including any complaints which he may have drafted." Annexed hereto as Exhibit 16 and made a part hereof, are three (3) excerpts from the video tapes which indicate Armstrong's intention to manufacture testimony if necessary.

28. Armstrong also devised an elaborate blackmail and extortion scheme to carry out his conspiratorial plan. This plan, called "Long Prong", was Armstrong's effort to set up a senior Scientologist with a woman in order to upset his marriage, degrade his reputation within the Church and blackmail his cooperation in Armstrong's scheme to subvert Church of Scientology management.

John Nelson

29. Defendants have also included a declaration by John Nelson dated September 24, 1984 where Mr. Nelson contended under oath that from December, 1981 until his removal from a staff position in 1982, L. Ron Hubbard was running the Church of Scientology. Annexed hereto as Exhibit 17 is the April 18, 1985 declaration of Joseph Yanny, a California attorney, submitted in the Founding Church cases in which he describes the April 3, 1985 deposition which he conducted of John Nelson. Mr. Nelson's April 3 testimony conflicts with the


1984 declaration relied on by this Court in its opinion; Mr. Nelson now asserts that he was “head of the Church" in 1982, and that he [Nelson], not L. Ron Hubbard, was assigned "[t]o run the Church. Oversee it. I was an administrator,“ and that he "was the top administrator in the Church.“ See Exhibit 17, Paragraph 5, and annexed excerpt of transcript. In that deposition Mr. Nelson testified:

Q. Did you ever hold any posts as they are called in the Church?

A. Sure.

Q. What posts?

A. I held many posts culminating in head of my Church in 1982.

Q. You were the head of the Church?

A. Yes.

William Franks

31. Similarly, the declaration of William Franks filed in another case, Church of Scientology v. Michael Flynn, C.A. No. 5052R (C.D. Ca1.), but submitted by defendants in this action, is not credible. The Declaration of Howard Gutfeld, Exhibit 18 concerning Mr. Franks' testimony in Julie Christofferson-Titchbourne v. Church of Scientology, Mission of Davis, et al., (Circuit Court Oregon), ("Christofferson"), notes that (1) Mr. Franks testified in Christofferson that in an address to Church Mission Holders in December, 1981, he had stated he had not been appointed to be Executive Director International by L. Ron Hubbard; (2) Mr. Franks testified in Christofferson that he had not met with Mr. Hubbard since 1975 and that his last written communication from L. Ron


Hubbard was in August of 1981; (3) Mr. Franks testified in Christofferson that he was the most senior executive of the Church of Scientology while Executive Director International and that he was managing Scientology during his tenure as Executive Director International; and (4) Mr. Franks testified in Christofferson that he had thought L. Ron Hubbard was "off the [command] line“ as of March, 1980. See, Gutfeld Declaration, Exhibit 18 at paragraphs 5, 7, and 8.

Under these circumstances, Mr. Franks' declaration concerning events three years prior to the date Mr. Hubbard's deposition was noticed in this action should not be relied upon by the Court as it is contradicted by Mr. Franks' recent sworn testimony under cross-examination in the Christofferson trial.

During the Christofferson trial, Laurel Sullivan contradicted Franks' sworn statement in his Declaration of December, 1980 that he had been appointed to the position of Executive Director International of the Church of Scientology by L. Ron Hubbard. Ms. Sullivan testified under oath to the contrary:

Q: When was Bill Franks made Executive Director International?

A: I guess it was late '80.

Q: Who made him Executive Director International?

A: The Watchdog Committee and myself.

(See Christofferson transcript, Exhibit 30.)

Moreover, Mr. Franks averment that Mr. Hubbard runs the Church is also flatly contradicted by his previous statements to the media as recently as 1983 that Mr. Hubbard has been dead since 1981 and that the new leaders of Scientology "are perpetuating a myth" that Mr. Hubbard "is still alive and in touch with them." See Plaintiffs


Exhibit 19. This false contention was put forward at that time by Mr Franks to conveniently support a probate action brought by Mr. Hubbard's estranged son, who was represented by Mr. Flynn (who incidentally has been listed by defendants here as being of counsel), to have Mr. Hubbard declared legally incompetent or dead in order to take control of his estate. When this position was emphatically rejected by the Court in In Re Estate of L. Ron Hubbard, A Missing Person, Case No. 4715 (June 27, 1983 Sup. Ct. Cal.), this manufactured story was discarded only to be replaced by a new manufactured story to fit current strategy to make it appear that L. Ron Hubbard controls the Church despite clear and convincing evidence to the contrary.

Warren Friske

32. Defendants have also submitted the declaration of Warren H. Friske which was executed on July 7, 1982 and submitted in the case of La Vanda Van Schaick vs. Church of Scientology of California, Ca. No. 79-2491 in the United States District Court for the District of Massachusetts. As with the declaration of Kima Douglas, this document does not relate in any manner to the question presented to this Court as to whether L. Ron Hubbard is presently an officer, director or managing agent of any of the Plaintiffs. The submission of this declaration is an obvious ploy to enter into evidence before this Court as many negative items about the Church as possible. The irrelevance of these declarations apparently has not escaped this Court's attention as evidenced by the fact that this Court did not even mention those individuals in its prior ruling.

33. Most of these witnesses, e.g., Armstrong, Franks, Sullivan, Friske and Douglas have an important attribute in common:


they all are closely associated with, and in many instances represented by, a Boston attorney, Michael Flynn. For the last seven years Flynn has been engaged in an intensive campaign to destroy the Church of Scientology. One of his schemes to accomplish this involved the creation of the Flynn Associates Management Corporation (FAMCO) which would be a vehicle for raising money to fund his anti-Scientology litigation, including the sale of stock. As explained in the Affidavit of Jim Grey, the purpose of FAMCO was to "raise and disburse monies which would be used to file suits against the Church of Scientology around the country and therefore break the Church financially." See Plaintiffs' Exhibit 24. As revealed in FAMCO's own documents, Flynn envisioned bringing 1,000 lawsuits against the Church. See Plaintiffs' Exhibit 25.

34. Exhibit 1 submitted by Plaintiffs is a true and exact copy of an assignment of rights from L. Ron Hubbard to the Religious Technology Center dated June 15, 1982.

Exhibit 2 submitted by Plaintiffs is a true and exact copy of Page 6946 of the trial transcript in the case of Julie Christofferson-Titchbourne vs. Church of Scientology of Ca1ifornia et al. in the Oregon Circuit Court, County of Multnomah, Case No. A7704-O5l84.

Exhibit 3 submitted by Plaintiffs is a true and exact copy of the deposition testimony of Laurel Sullivan (then, Laurel Watson) in the Case of Times Publishing Co. et al. vs. Church of Scientology et al.

Exhibit 4 submitted by Plaintiffs is a true and exact copy of Page 3027 of the trial transcript of Church of Scientology of California vs. Armstrong.


Exhibit 5 submitted by Plaintiffs is a true and exact copy of Page 52 of the deposition of Laurel Sullivan in the case of Times Publishing Co., et al. vs. Church of Scientology, et al.

Exhibit 6 submitted by Plaintiffs is a true and exact copy of Page 3124 of the trial transcript of Church of Scientology vs. Armstrong.

Exhibit 7 submitted by Plaintiffs are true and exact copies Pages 52-53 of deposition testimony of Laurel Sullivan in Church of Scientology of California et al. v. Lingberg, et al.

Exhibit 8 submitted by Plaintiffs are true and exact copies Pages 35-36 of deposition testimony of Laurel Sullivan in Church of Scientology of California, et al. v. Linberg, et al.

Exhibit 9 submitted by Plaintiffs is a true and exact copy of a communication put out by the Commodore's Messenger Organization on July 19, 1981.

Exhibit 10 submitted by Plaintiffs is a true and exact copy of the deposition testimony of Diana Reisdorf-Voegeding in the case of Church of Scientology of California vs. Linbergh in the United States District Court for the Central District of California.

Exhibit 11 submitted by Plaintiffs is a true and exact copy of the transcript of a video recording of a conversation involving Gerald Armstrong on November 17, 1984.

Exhibit 12 submitted by Plaintiffs is a true and exact copy of the transcript of a video recording of a conversation involving Gerald Armstrong on November 7, 1984.

Exhibit 11 submitted by Plaintiffs is a true and exact copy of the transcript of a video recording of a conversation involving


Gerald Armstrong on November 9, 1984.

Exhibit 14 submitted by Plaintiffs is a true and exact copy of an excerpt of the video taped conversations of Gerald Armstrong.

Exhibit 15 submitted by Plaintiffs is a true and exact copy of an excerpt of the video taped transcripts of a conversation with Gerald Armstrong.

Exhibit 16 submitted by Plaintiffs is a true and exact of an excerpt of the video taped transcripts of a conversation with Gerald Armstrong.

Exhibit 17 submitted by Plaintiffs is a true and exact copy of a declaration submitted by Joseph A. Yanny submitted in The Founding Church of Scientology of Washington, D.C,, et al. vs. Director of FBI, et al., Civil Action No. 78-0107 in the United States District Court for the District of Columbia.

Exhibit 18 submitted by Plaintiffs is a true and exact copy of an Declaration of Howard Gutfeld.

Exhibit 19 submitted by Plaintiffs is a true and exact copy of a news article published in the Los Angeles Times dated January 17, 1983.

Exhibit 20 submitted by Plaintiffs is a true and exact copy of an Order entered October 27, 1980 in the case of Church of Scientology of California, et al. vs. Siegelman, et al., Case No. 79-CIV-116 in the United States District for the Southern District of New York.

Exhibit 21 submitted by Plaintiffs is a true and exact copy of an Order entered October 8, 1985 by the Honorable Charles E. Jones in the case of Church of Scientology of California vs. Jordan, et


al., Civil Action No. C538049 in the Superior Court of the County of Los Angeles, State of California.

Exhibit 22 submitted by Plaintiffs is a true and exact copy of the Affidavit of Paulette Cooper submitted in Church of Scientology v. Flynn, Civil Action No. 83-5052R in the U.S. District Court for the Central District of California.

Exhibit 23 submitted by Plaintiffs is a true and exact copy of the declaration of L. Ron Hubbard submitted by L. Ron Hubbard in In re Estate of Hubbard, executed on May 15, 1983.

Exhibit 24 submitted by Plaintiffs is a true and exact copy of an Affidavit of Jim Grey.

Exhibit 25 submitted by Plaintiffs is a true and exact copy of a FAMCO document revealing the plan to bring 1,000 lawsuits against the Church of Scientology.

Exhibit 26 submitted by Plaintiffs is a true and exact copy of an Affidavit of Paulette Cooper.

Exhibit 27 submitted by Plaintiffs is a true and exact copy of an Affidavit of Paulette Cooper.

Exhibit 28 submitted by Plaintiffs is a true and exact copy of the Order of Contempt by Judge Hennigan In re Estate of Hubbard, dated July 19, 1983.

Exhibit 29 submitted by Plaintiffs is a true and exact copy of Order Denying Pro Hac Vice Application of Michael J. Flynn by Judge Hennigan in the case In re Estate of Hubbard, dated March 22, 1983.

Exhibit 30 submitted by Plaintiffs is a true and exact copy of


a portion of the transcript of Laurel Sullivan's testimony during the trial of the case of {Julie Christofferson-Titchbourne vs. Church of} {Scientology of California et al.}

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Executed this 15th day of December, 1985 at Los Angeles, California.