Making Light of Black PR, Part 5,
January 13, 1994 Armstrong Declaration in C$I v. Armstrong.
[6 March 2000]

January 13, 1994 Armstrong Declaration in C$I v. Armstrong.

From: Gerry Armstrong <>
Newsgroups: alt.religion.scientology
Subject: Making Light of Black PR, Part 5, January 13, 1994 Armstrong Declaration in C$I v. Armstrong.
Date: Mon, 06 Mar 2000 08:14:06 GMT
Message-ID: <>

Making Light of Black PR, Part 5, January 13, 1994 Armstrong
Declaration in C$I v. Armstrong.


A Literary Work Created and Written

Copyright © 1994 Gerald Armstrong
All Rights Reserved

© 2000 Gerry Armstrong


I, Gerald Armstrong, declare:

1. I am a defendant in the case of Church of Scientology
International v. Gerald Armstrong, Michael Walton and The
Gerald Armstrong Corporation, Marin Superior Court case no.
157680, filed July 23, 1993, hereinafter "Armstrong IV." I am
making this declaration for all purposes, including the
disposing of the Armstrong IV complaint, which, for literary
purposes, is appended hereto as Exhibit A.

2. I am a defendant in the case of Church of Scientology
International v. Gerald Armstrong and The Gerald Armstrong
Corporation, Los Angeles Superior Court case no. BC 084642,
hereinafter "Armstrong III," filed July 8, 1993. I am a
defendant and cross-complainant in the case of Church of
Scientology International v. Gerald Armstrong and The Gerald
Armstrong Corporation, Los Angeles Superior Court, filed
February 4, 1992, in Marin Superior Court as case no. 152229,
and transferred March 20, 1992 to Los Angeles Superior Court
and given case no. BC 052395, hereinafter "Armstrong II." I am
the defendant and cross-complainant in the case of Church of
Scientology of California and Mary Sue Hubbard v. Gerald
Armstrong, Los Angeles Superior Court case no. C 420153,
hereinafter "Armstrong I," filed August 2, 1982.

3. I am a writer, artist and philosopher. I am the founder of
and present majority shareholder in The Gerald Armstrong
Corporation, hereinafter "TGAC," also named as a defendant in
Armstrong II, III and IV. I am the sole office support of
attorney Ford Greene in San Anselmo, California. Mr. Greene
represents me in Armstrong IV, and, along with attorney Paul
Morantz of Pacific Palisades, California, in I, II and III.

4. I was involved inside the Scientology organization,
hereinafter the "organization," from 1969 through 1981
and held many staff positions in the Sea Org, Scientology's elite
quasiparamilitary core. I gained a knowledge of organization
policies and operations, worked closely for period with its
founder and leader L. Ron Hubbard, and during my last two years
inside did the research for a biography to be written about the
man. I have detailed my organization experiences in many
declarations and have testified in organization litigation in
depositions and at trials approximately 55 days in some 20
lawsuits from 1982 through 1993.

5. On June 20, 1984, following a lengthy bench trial in
Armstrong I, LA Superior Court Judge Paul G. Breckenridge, Jr.
issued a memorandum of intended decision, a copy of which is
appended hereto as Exhibit B. Finding in my favor, he wrote,
inter alia: "In addition to violating and abusing its own
members civil rights, the organization over the years with its
"Fair Game" doctrine has harassed and abused those persons
not in the [organization] whom it perceives as enemies. The
organization clearly is schizophrenic and paranoid, and this
bizarre combination seems to be a reflection of its founder
LRH. The evidence portrays a man who has been virtually a
pathological liar when it comes to his history, background and
achievements. The writings and documents in evidence
additionally reflect his egoism, greed, avarice, lust for
power, and vindictiveness and aggressiveness against persons
perceived by him to be disloyal or hostile." (Ex. B, at p. 8,
l. 18) On July 20, 1984 Judge Breckenridge ordered that his
intended decision be deemed his statement of decision, and on
August 10, 1984 entered it as judgment. The organization

6. On July 29, 1991 the California Court of Appeal, Second
District, Division 3 issued its opinion, a copy of which is
appended hereto as Exhibit C, affirming the Breckenridge
decision. The Court of Appeal stated, inter alia, that the
organization's "suppressive person declares" had "subjected
Armstrong to the 'Fair Game Doctrine' of the [organization]
which permits a suppressive person to be 'tricked, sued or lied
to or destroyed...[or] deprived of property or injured by any
means by any Scientologist....'" (Ex. C, Church of Scientology
v. Armstrong, 283 Cal. Rptr. 917, at p. 920)

7. The Armstrong I cross-complaint, which, on the
organization's motion had been bifurcated from the underlying
case before the 1984 trial, settled in December, 1986.
Armstrong II and III are breach of contract actions for damages
and enforcement of the conditions of the central document in
the settlement entitled "Mutual Release of All Claims and
Settlement Agreement," hereinafter the "settlement agreement,"
which the organization has attached as an exhibit to its
Armstrong IV complaint, and which is appended hereto as Exhibit

8. I am an expert in the identification of the organization's
fraudulent nature, practices and statements, and "fair game,"
the organization's fundamental philosophy and practice of
opportunistic hatred, and I have testified as an expert in
these areas. Because of what I know and my willingness to
communicate freely to anyone who wants to hear, I am fair
game's target. I have been subjected to the organization's
cynical and dangerous legal and extralegal operations from 1982
to the present. I have documented dozens of instances of fair
game in action toward me in my earlier declarations and oral
testimony. See, for example, paragraphs 6 through 9 and 19 and
20 of my declaration of March 16, 1992, a copy of which is
appended hereto as Exhibit E, filed in Armstrong II in Marin
County in opposition to Scientology's motion for a preliminary
injunction. The Armstrong IV lawsuit is another instance of
fair game. It is based on the perjurious statements of
organization lawyer Andrew H. Wilson, it is meritless and

9. The central charges of the Armstrong IV complaint are that:
(a) beginning in February, 1990, and continuing until the
present I wilfully and repeatedly violated the settlement
agreement; (b) fearing that the organization would seek to
collect the damages, which it claims to be due pursuant to the
settlement agreement's liquidated damages clause, I conspired
with Michael Walton to fraudulently convey to him in August
1990 my interest in the real property situated at 707 Fawn
Drive in Sleepy Hollow, Marin County, California, for the
purpose of rendering myself "judgment-proof;" (c) in 1988 I
transferred my material assets to TGAC at the time I embarked
on a campaign to harass the organization with the intention of
preventing the organization from collecting money from me
pursuant to the liquidated damages clause, and that TGAC exists
solely to make me judgment-proof; (d) in August, 1990 I
transferred to Michael Walton cash and stock in TGAC with the
intent to defraud the organization in the collection of its
damages; and (e) the organization should get $4,800,000.00 for
all this fraud.

10. I will deal first with certain specific averments in the
complaint; then with certain material facts which the
organization and its lawyer, Mr. Wilson, were aware of before
filing the verified complaint, but which have been disregarded
in favor of fakery; and finally I will provide additional
material facts and documentation to fill in any gaps in the
historical events and their context which underlie the
complaint and support the inevasible conclusion that it is
frivolous, malicious and should be dismissed.

11. Mr. Wilson states: "Armstrong, a former Church member
who sought, by both litigation and covert means, to disrupt the
activities of his former faith, displayed through the years an
intense and abiding hatred for the Church, and an eagerness to
annoy and harass his former co-religionists by spreading enmity
and hatred among members and former members." (p. 2, l.4) The
organization, as it has been and is operated, is not a church.
It is neither a house of worship of God, nor a sanctuary for
His children. Moreover, in Hubbard's claims of scientific
verifiability for his prohibitive psychotherapy he insisted
specifically that Scientology's efficacy did not, unlike
religion, depend on faith. My Scientology involvement since I
left from inside in 1981 has been with the organization's power
structure; that is, the few who control all personnel,
communication and finance units and decisions, the
organization's litigation machine, intelligence and propaganda
bureaus, its private investigators, and all of those segments'
dirty tricks. My message has been that the power structure's
policies and actions to harass and destroy labeled enemies, its
doctrine of opportunistic hatred, and its spreading of enmity
are not religious, not effective, and have only brought the
organization and Hubbard inevitable ignominy. My message is
that the only religious act in the world is forgiveness, that
Hubbard lied when he defined forgiveness as "condemnation,"
that he miscalculated madly when he attempted to program
himself with the idea that all men were his slaves, and then
acted as if they were, and that the organization could just as
easily be engaged in the emancipation of its members as their
enslavement. I do not urge enmity among its members and former
members even toward the policies and practices of defrauding
and brutalizing the innocent, but do urge understanding and
forgiveness. That I disrupt the power structure's activities -
its rewriting of history, daily fraud, mockery of religion, use
of the law to harass, assault on our justice system, abuse of
the good, bullying of the weak, and intimidation of those who
should be the weak's defenders - I admit. These antisocial
activities will continue to be disrupted until the organization
realizes that such activities simply don't work, and out of
self-interest forsakes the litigation business, discontinues
the war on the innocent, and either becomes religion or drops
that immodest mantle. But the disruption flows only from the
organization's own antisocial actions, which rebound on their
manufacturer if any target stands up, doesn't duck and is
willing to take a few hits. I have no intelligence bureau,
propaganda apparatus, private investigators, litigation machine
and no hundreds of millions to finance them. I have no fair
game policy, and no underlings to implement it if I did have
one. I have no lawyers willing to lie for a little lucre and no
operatives to steal documents, frame judges, compromise jurors,
trick, sue or destroy invented and then targeted "enemies."
Scientology's power structure is a big, black pot desperately
seeking kettles to tarnish.

12. Mr. Wilson states: "[the organization] sought, with the
Agreement, to end all of Armstrong's covert activities against
it, along with the litigation itself." (p. 2, l. 9) I had no
covert activities against the organization. It is the
organization with its army of agents, private investigators and
lawyer cutouts which carries on its periculous, albeit
ridiculous, covert war. Hubbard patterned his espionage
apparatus on the system developed by Hitler's spy master,
Reinhard Gehlen, and the power structure has continued
Hubbard's dark and secret methods to this day. The organization
did not seek to end the litigation with me, and has not sought
to end its use of litigation to achieve its global antisocial
goals. It sought to silence me with threats and eliminate my
ability to defend myself by contracting away from me my own
attorneys, Michael Flynn of Boston, Massachusetts and Contos &
Bunch of Woodland Hills, California, who had represented me
throughout the Armstrong I litigation, so that it could keep
its litigation machine running, continue to obstruct justice,
use the law to harass, deny redress to its victims, and
steamroll its opposition. Hubbard and his organization had
ruthlessly and unremittingly attacked Mr. Flynn, my good friend
and the prime mover for seven years in a national effort to
bring Scientology to justice, suing him some fifteen times,
filing false bar complaints against him, infiltrating his
office, stealing documents, framing him with the forgery of a
$2,000,000 check, libeling him internationally, and, according
to Mr. Flynn, attempting his assassination. The organization
threatened his law practice, family and life, hurt his
marriage, and finally forced him, in his desperation to end the
threats, to sign a contract with the organization to not help
me should the organization attack me after the contract's
signing. Even its own settlement agreement (Ex. D) belies the
organization's claim that it sought to end the Armstrong I
litigation. Paragraph 4B allows the organization, following the
December, 1986 settlement, to maintain the appeal from the
Breckenridge decision, while requiring me to obstruct justice
by not opposing any future appeals. Coupled with the likewise
illegal contracts requiring my attorneys to not represent me in
any such future appeals or in any action by the organization to
enforce the settlement agreement, the agreement's intended
effect was to remove any opposition to the organization's
litigation juggernaut. My attorneys' signing of the
non-representation contracts is understandable and wholly
excusable when the threat of the organization's attacks on them
is understood.

13. Mr. Wilson states: "the Agreement contained carefully
negotiated and agreed-upon confidentiality provisions and
provisions prohibiting Armstrong from fomenting litigation
against [the organization] by third parties." (Ex. A. p. 2, l.
12) This is the big black pot feigning blindness by its layers
of autogenous soot. The organization is very likely the most
litigious entity this world has ever known. I have consistently
done whatever I could to unfoment its litigation; in fact I
have adjured it to get out of the litigation business
completely, and to seek solutions to its problems through
peaceful means and open and honest communication. So far it
refuses to communicate with its targets, hides behind corrupt
lawyers, and rejects openness and honesty in favor of
luciferian litigiosity. Fomenting litigation is one of the
organization's principal weapons in its war against its
victims, its critics, the justice system and the world. The
declaration of U.S. District Court Judge James M. Ideman dated
June 17, 1993, a true copy of which is appended hereto as
Exhibit F, shows one respected jurist's insight into the
organization's abuse of the legal process and its fomentation
of litigation:

"[the organization's] noncompliance [with the Court's orders]
has consisted of evasions, misrepresentations, broken promises
and lies, but ultimately with refusal. As part of this scheme
to not comply, the [organization has] undertaken a massive
campaign of filing every conceivable motion (and some
inconceivable) [Judge Ideman's parens in original] to disguise
the true issue in these pretrial proceedings. Apparently
viewing litigation as war, [the organization] by this tactic
[has] had the effect of massively increasing the costs to the
other parties, and, for a while, to the Court. The appointment
of the Special Master 4 years ago has considerably relieved the
burden to this Court. The scope of [the organization's] efforts
have to be seen to be believed..... Yet it is almost all
puffery -- motions without merit or substance." (Ex. F, p. 2,
para 4, 5; filed June 21, 1993 in Religious Technology Center,
Petitioner v. U.S. District Court, Respondent, David Mayo, Real
Party in Interest, No. 93-70281 in the 9th Circuit Court of

14. Mr. Wilson states: "In or about February, 1990, Armstrong
began to take a series of actions which directly violated
provisions of the Agreement." (Ex. A., p. 2, l. 20) In the fall
of 1989, at the time I received a series of threats from
organization lawyer Lawrence E. Heller, and after enduring
without response almost three years of post-settlement fair
game, I came to the conclusion that by allowing myself to be
intimidated by the threats I would be abetting the
organization's obstruction of justice, and that I had an
inalienable right, and arguably even a duty, regardless of
whatever the settlement agreement said, to not obstruct
justice. My first action, and my only action, in February,
1990, was to petition the California Court of Appeal, Second
District, Division Three for permission to respond in the
appeal, No. B 025920, from the 1984 Breckenridge decision,
which the organization had been able to maintain during all the
intervening years. At the same time I petitioned Division Four
of the Second District for permission to respond in another
appeal, No. B 038975, that the organization had taken from a
1988 Los Angeles Superior Court order granting the motion of
contra-organization litigant Bent Corydon to unseal the
Armstrong I court file , which had been sealed since the
December, 1986 settlement. The organization opposed both
petitions, Division Three granted the petition to respond in
the appeal from Breckenridge, and I filed a reply in Division
Four to the opposition in the unsealing appeal, supported by a
declaration dated March 15, 1990, in which I detailed many of
the organization's post settlement threats and attacks and
stated my position regarding the unenforceability of several
conditions of the settlement agreement. The March 15, 1990
declaration, along with the exhibits thereto, except for the
Breckenridge decision (Ex. B to this declaration), is appended
hereto as Exhibit G. Since my documents were filed openly in
the appeals and served on all opposing counsel, the
organization is fully aware of what I did in 1990, and that I
had the Court of Appeal's permission to do it. Mr. Wilson's
allegation that I began in February, 1990 to directly violate
the settlement agreement contradicts an earlier allegation the
organization and Mr. Wilson made in the Armstrong II pleadings.
In the amended complaint filed June 4, 1992, a copy of which is
appended hereto as Exhibit H, the organization states:

"As soon as he finished spending the money he extracted from
[the organization] as the price of his signature, in June,
1991, Armstrong began a systematic campaign to foment
litigation against [the organization] by providing confidential
information, copies of the Agreement, declarations, and
"paralegal" assistance to litigants actively engaged in
litigation against his former adversaries." (Ex. H, p. 2, l.

The June, 1991 date would not work well in the organization's
Armstrong IV fraudulent conveyance figment, so the February,
1990 starting date for my "violations" was fabricated.
Similarly the allegation would not work that as soon as I had
finished spending the settlement money I began whatever I did
that the organization calls in its various documents a
"systematic campaign." I could have spent the money; I could
have fraudulently conveyed my assets; I couldn't have done
both. I did neither. Nor did I begin a campaign, systematic or
not, to foment litigation against any of the organization's

15. Mr. Wilson states: "Fearing that [the organization] would
seek to collect the liquidated damages owed by his breaches,
Armstrong, .... fraudulently conveyed all of his property,
including real property located in Marin County, cash, and
personal property to defendants Michael Walton, the Gerald
Armstrong Corporation, and Does 1-100, receiving no
consideration in return." (Ex. A. p. 2, l. 22) I have never
feared the organization collecting damages of any kind against
me, nor even its seeking to collect damages. I do have an
undeniable concern that before it comes to its senses or saner
minds prevail in the organization the power structure will have
me assassinated or do something else diabolical and dangerous,
and this has produced in me an awareness of threat and is a
fact of my present psychological condition. These people are
quite capable of violent and criminal acts, they are armed, and
their head private investigator, Eugene M. Ingram, a former
LAPD vice sergeant, who is reported to have been busted from
the force for pandering and taking payoffs from drug dealers,
in 1984 threatened to put a bullet between my eyes, and in
November, 1993 spread the rumor in broad daylight that I have
AIDS. But I have never feared that the organization can win in
court or ever be awarded damages against me. I do not believe
any court in this country will order me to obstruct justice,
not defend myself, nor even not profit monetarily from, much
less communicate about, on-going, open-court lawsuits in which
I have been sued for millions of dollars. The organization
operates in pretended blindness to the way rational people view
its litigiousness, its abuse of process, its greed and its
suppression of its members' decent natures. My conveyance of
707 Fawn Drive to Michael Walton, my forgiving of debts owed to
me, and my giving away of cash, personal effects and TGAC stock
were not motivated by fear of the organization perhaps suing me
and conceivably, although not beyond improbably, being awarded
monetary damages in any such lawsuit. To the contrary, I
believe that should any of the Armstrong II, III or IV cases go
to trial I will be awarded attorney's fees, costs and damages,
and that either the organization will agree to rescind the
settlement agreement's unfair and unenforceable clauses or our
courts will rule them illegal. I had believed throughout 1990
and 1991 that it was entirely likely that the organization
would never sue me, even after attorney Heller's threats of
litigation, since it had to know that it could never win in an
uncompromised court, and that any lawsuit it might bring
against me would only bring it further disgrace. I gave away my
assets after a great deal of contemplation, which included
acceptance of the fact that thereafter if I stood up against
injustice I would have to stand up to the organization, and for
that matter any organization, individual, army or nation,
essentially penniless. My amended answer to the Armstrong II
amended complaint, a copy of which is appended hereto as
Exhibit I, filed and served on Mr. Wilson October 8, 1992,

"Armstrong denies that he ever extracted money from the ORG.
Armstrong denies that in June, 1991 he had finished spending
his money. In August 1990 Armstrong had given away all his
assets for reasons unrelated to the ORG, except that he
evaluated that because the ORG committed so much harm with its
billions of dollars there was no reason not to give his money
away, and that it was better to combat the ORG's tyranny
without money than not to combat it with wheelbarrow loads of
it. Armstrong denies that in June, 1991 he began any campaign,
provided any confidential information to anyone, copies of any
agreement, declarations, and paralegal assistance to any
litigants." (Ex. I. p. 3, para. 3, l. 23)

I believe that in exchange for my willingness to renounce what
were my worldly assets in August, 1990, I have received
consideration far beyond what I imagined at the time. I could
not and did not attempt to predict in August, 1990 what would
happen in the years that have followed. I proceeded with the
faith that our Creator was the Source of the idea of
renunciation and that I could trust Him to guide me and care
for all my needs. The subsequent years have shown me that my
willingness flowed from His grace and that my trust was
exceedingly well placed.

16. Mr. Wilson states: "Armstrong caused his own personal
assets to be transferred to [TGAC] without adequate
consideration in order to evade payment of his legal
obligations, and defendant Armstrong has completely controlled,
dominated, managed and operated [TGAC] since its incorporation
for his own personal benefit." (Ex. A. p. 4, l. 15)

"Armstrong transferred his material assets to [TGAC] in 1988,
at the time of his embarkation on the campaign of
harassment..., and with the intention of preventing [the
organization] from obtaining monetary relief from Armstrong
pursuant to the liquidated damages clause. Hence [TGAC] exists
solely so that Armstrong may be "judgment proof." (Ex. A., p.
5, l. 3)

Again to make irrefutable facts fit his fraudulent conveyance
fiction, Mr. Wilson has, frankly, fudged. I incorporated TGAC
in 1987 and activated it at the beginning of 1988. At that time
I also transferred to the corporation all my drawings and other
artwork, writings, rights thereto, office equipment and
supplies, and I provided startup capital. In exchange I
received one hundred percent of TGAC's stock. Mr. Wilson's
conclusion that one hundred percent ownership of the
corporation which owned my products, rights to their commercial
exploitation, plus office materiel was not adequate
consideration for those products, rights and materiel, is
dissemblingly dense. His allegation that I embarked in 1988 on
a campaign of harassment is duplicitously daft. Yet this is
utterly unsurprising standard Scientological operating
procedure. Very simply, the organization requires its members
and its lawyers to lie; and should they ever decide to stop
lying, its members and lawyers become fair game. The only thing
I did in 1988 regarding the organization was to remain silent
in the face of its continuing post-settlement threats and
attacks. Mr. Wilson's assertion that TGAC exists solely to make
me judgment proof, if it were not being made by an officer of
the court under the paw of the pestiferous power structure of
this contumelious cult for its pernicious purposes of revenge,
fair game, black propaganda, attack on my friends, waste of
everyone's time, and my psychological and economic destruction,
would just be faintly funniferous flapdoodle.

17. Mr. Wilson states: "The consideration paid to Armstrong
was fair, reasonable and adequate." (Ex. A., p. 7, l. 1) I
agree that the consideration was reasonable. The organization
paid me as recompense for its fraud and abuse over the more
than twelve years I devoted to L. Ron Hubbard and for the five
years of fair game harassment after I left. It settled with me
out of court in December, 1986 rather than face the trial of my
Armstrong I cross-complaint, then set for March, 1987. It again
defrauded me at the time of the settlement because it
represented, through my attorney Michael Flynn, that it was
discontinuing fair game and getting out of the litigation
business. It did not pay me, nor did it even offer to pay me,
to be fair game's willing victim and a tool the rest of my life
in its abuse of our justice system and suppression of our

18. Mr. Wilson is aware of the truth behind his untruthful
statements in the Armstrong IV complaint, but has chosen, in
order to forward his client's malicious intentions, to ignore
that truth. He is aware, as shown in paragraph 14 above, since
he is an attorney of record in the case, that in the Armstrong
II complaint the organization has claimed that in June, 1991 I
began what it calls "a systematic campaign to foment
litigation." Mr. Wilson, as shown in paragraph 15 above, is
also aware that I stated in my answer in Armstrong II that I
had given away my assets in August, 1990, for reasons unrelated
to the organization. These reasons are in truth irrelevant to
any of the organization's claims in any of the Armstrong cases,
but incredibly have been made relevant by Mr. Wilson due to his
dishonest insistence, in order to justify his further
harassment of me with the filing of Armstrong IV, that my
renunciation was the product of some conspiracy to defraud the
organization that pays him to attack me.

19. In my deposition in Armstrong II taken on July 22, 1992 by
Mr. Wilson, pages 266 through 270 from the transcript of which
are appended hereto as Exhibit J, the following exchanges

(For clarity I have integrated into the quoted sections the
corrections I made in the deposition transcripts in my review
of my testimony pursuant to the California Code of Civil

"Q. (Mr. Wilson) How about this, why don't you just tell me,
tell me the business of the Gerald Armstrong Corporation is.

A. (Me) The Gerald Armstrong Corporation possesses a number of
Gerald Armstrong's artistic and literary works, possesses
rights to a number of his inventions and rights to certain
formulas, and is in the business of bringing peace and
exploiting its assets for commercial and peaceful purposes.

Q. Okay. What does it do to exploit its assets for commercial
purposes? Make anything, sell anything?

A. It sells things and it makes things.

Q. What does it make.

A. It makes sculptures, cards, works of art, literary works,

Q. What campaigns does it make?

A. It is a contributor and possessor of certain rights within
the group known as the Runners Against Trash and the same
within the organization known as the Organization of United

Q. What is the Organization of United Renunciants?

A. It is an organization dedicated to the preservation of the
world through peaceful means.

Q. What have the people in the organization renounced, if

A. The people in the organization renounce money.

Q. Does that mean they give away their money?

A. They can if they want.

Q. Did you give away the money that the Church paid you in

A. Well, I'm, that's not a very well worded question, because
I gave away all my assets including my money.

Q. When?

A. When? August 1990.

Q. Who did you give it to?

A. A number of people.

Q. Can you tell me who they are?

A. No.

Q. Did you give any of it to Michael Walton?

A. Yes.

Q. Why did you give it away?

A. Because I considered that I was guided to do so.

Q. By whom?

A. The Source of all that is.

Q. Who is that?

A. God.

Q. Now when God guided you to give away all your assets, did
[H]e guide you to give them to particular people or did you make that

A. I believe that I was guided each step of the way.

Q. Okay. When you say you gave it away, I take it you didn't
receive anything in return in terms of monetary compensation?

A. Right.

Q. Can you tell me why you decided to give some of it to
Michael Walton?

A. Because it was logical.

Q. Why?

A. And because I was so guided.

Q. Can you tell me what about it was logical?

A. I guess initially it's logical because he was a friend of
mine in close proximity to me, and I believed that he had a
need at that time." (Ex. J. p. 266, l. 12 - p. 269, l. 3)

20. In my deposition in Armstrong II taken on October 8, 1992
by Scientologist lawyer Laurie J. Bartilson, Mr. Wilson's
co-counsel in II, III and IV, pages 459 through 475 from the
transcript of which are appended hereto as Exhibit K, the
following exchanges occurred:

" Q. (Ms. Bartilson) And if I ask you how much of the proceeds
were still remaining in your pocket at some period later when
you gave away all of your assets on the instruction of God, you
won't tell me that either, correct?

A. (Me) Correct. (Ex. K. p. 460, l. 25 - p. 461, l. 4)

Q. Does the Gerald Armstrong Corporation have any material

A. Yes.

Q. Generally what are those assets, categories of things?

A. It owns original artwork and it has rights, inasmuch as
such are assertable, in certain inventions and formulas. (Ex. K. p.
463, l. 12 - l. 24)

Q. What is its (TGAC's) function?

A. It cares for, archives, promotes and exploits the works of
Gerald Armstrong, and it is a vehicle for peace." (Ex. K. p. 469, l.
19 - l. 22)

21. In my deposition in Armstrong II taken on March 10,
1993 by Ms. Bartilson, pages 555 through 557 from the transcript of
which are appended hereto as Exhibit L, the following exchange

" Q. Did you transfer that large body of work to The Gerald
Armstrong Corporation in August of 1990?

A. No. The Gerald Armstrong Corporation already owned those

Q. So was it The Gerald Armstrong Corporation transferring it
Away or the right to it away?

A. The Gerald Armstrong Corporation owned a number of things.
I gave away the corporation. The corporation possessed a number of

Q. So at the beginning -- at the end of the transaction the
corporation still owned the assets, but different people owned The
Gerald Armstrong Corporation?

A. Correct.

Q. You are still a part-owner President of The Gerald
Armstrong Corporation, are you not?

A. I am now.

Q. But you were not in August of 1990?

A. Correct.

Q. You have since reacquired it?

A. Correct.

Q. How much of the stock do you presently own in The Gerald
Armstrong Corporation?

A. Eighty." (Ex. L, p. 556, l. 14 - p. 557, l. 11)

22. In the deposition of Michael Walton in Armstrong II taken
on February 23, 1993 by Mr. Wilson, pages 39 through 42 from the
transcript of which are appended hereto as Exhibit M, the following
exchanges occurred:

" Q. (Mr. Wilson) And he's never transferred any property to

A. (Mr. Walton) Yes, he has.

Q. What has he transferred to you?

A. He transferred his interest in Fawn Drive to me.

Q. And what consideration did you pay him for that?

A. None.

Q. It was a gift?

A. Yes.

Q. And when did that occur?

A. I think it was around the time of the Desert Storm. I
don't -- I really don't -- I'm not quite sure. I can tell you it was
-- it was approximately a year before the -- No, I can't tell you that
either. I'm really not sure.

Q. Do you know why he transferred it to you?

A. I know what he told me.

Q. What did he tell you?

A. I'm trying to remember it. Let me think about it and see
if I can remember under what circumstances. I don't believe this has
any relation to any representation. [G]erry told me that he'd had a
vision from God.

Q. That's it?

A. That's the reason. That's when he divested of all the
property that I know of." (Ex. M. p. 39, l. 9 - p. 40, l. 13)

23. On four days from the fall of 1991 through the spring of
1992 organization Scientologist attorney Kendrick Moxon, of
Bowles and Moxon, attorneys of record in Armstrong I, II, III
and IV took my deposition in Religious Technology Center,
Church of Scientology International and Church of Scientology
of California v. Joseph A. Yanny, Los Angeles Superior Court
case no. BC 033035, known in the Scientology litigation arena
as Yanny II. This case involved the organization's claim that
Mr. Yanny, formerly one of its lawyers, was representing me in
litigation against the organization. The claim was spurious,
invented as a way to attack Mr. Yanny and me, and the case was
dismissed by the Court before trial. The organization appealed
and on January 11, 1994 the California Court of Appeal, Second
Appellate District, Division Three affirmed the judgment of
dismissal (B068261). During my deposition of March 17, 1992,
pages 449 through 462 from the transcript of which are appended
hereto as Exhibit N, the following exchanges occurred:

" Q. (Mr. Moxon) Did Yanny ever give you any money? Has he ever
given you any money?


A. (Me) Mr. Yanny has bought some meals for me, Mr. Yanny has
paid for parking. He has not given me any money other than that.

THE REFEREE (Honorable Thomas T. Johnson): And you stayed in
his house?

A. Right

Q. Didn't he pay for you to come down to Los Angeles?

A. What that became was Mr. Yanny's purchase of stock in [T]he
Gerald Armstrong Corporation.

Q. Who owns the Gerald Armstrong Corporation?


A. The Gerald Armstrong Corporation is owned by stockholders,
and I decline to divulge who all the stockholders are.


THE REFEREE: The testimony is that there is a corporation. I
take it there have been questions in the past about the purpose of the
corporation. There is testimony that there are shareholders. More
than one shareholder I take it?

A. Yes, your Honor.

THE REFEREE: And that Mr. Yanny is a shareholder. Is Mr.
Yanny a majority shareholder?

A. No.

THE REFEREE: Without saying who the shareholders are, how many
shareholders are there?

A. I believe 12.

THE REFEREE: Are you a shareholder?

A. No, I'm not.

THE REFEREE: I'll sustain the objections to any further
questions on this shareholdings. Is the corporation registered with
the state of California?

A. Yes, your Honor.

THE REFEREE: How old is the corporation?

A. 1987.

THE REFEREE: Let's go on to something else.


Q. How much money did Yanny give you for stock in the Gerald
Armstrong Corporation?


A. $1,000.

Q. When did he give it to you?

A. My recollection is July and August or September, 1991.


Q. How many shares did that give Mr. Yanny?

A. One.

Q. One share?

A. One.

Q. Do the shares have any specific value?

A. $1,000.

Q. Did anybody else give you $1,000 to buy a share?

A. Yes.


THE REFEREE: What's the purpose of the inquiry?

MR. MOXON: The purpose is that I believe, and I would like to
explore, whether or not money has been acquired by Mr. Armstrong
through some improper means through a sham corporation that was
established for the purpose of paying him off for his work in relation
to the situation we're involved in, and potentially for his testimony.


THE REFEREE: Let me suggest another question. You can
certainly ask him whether a share of stock was issued for the

Q. Was a share of stock issued to Mr. Yanny?

A. It has his name on it. It has not been delivered to him yet.

Q. Why not?

I have not finished the artwork.

Q. Are you drawing the share?

A. No, the share is a printed share. Each share which I issue
has artwork on it. And I have not had the opportunity and I have not
... been in a place to perform that artwork.


Q. How many shares of stock does this corporation possess?

A. One hundred.

Q. What does Yanny get in exchange for his share of stock.

A. One percent ownership in the corporation.


THE REFEREE: What the purpose of the corporation? Somebody
went to the state and got permission to have a corporation. What's
the purpose of the corporation?

A. The corporation provides philosophic services. The
corporation owns all my literary and artistic works. It is my
expectation that the corporation will become profitable and [ ] those
people who have had the courage or wisdom to invest in the
corporation, as a result of the profitability of the corporation,

24. The idea of giving away my house, TGAC stock and other
assets, and forgiving all debts owed me, came to me in August, 1990.
This idea, which I consider Divinely inspired, came, I believe, in
answer to my prayer during that period requesting guidance concerning
humanity's condition, and specifically the then developing Middle East
crisis following Iraq's August 2, 1990 invasion of Kuwait. I was
moved by media reports of the invasion, the global tension, and the
daily events of Desert Shield, and I sought to know what, if anything,
God wanted me to do. The idea of renunciation of worldly wealth,
although coming at that time as a surprise, and unclear as to the
details for its accomplishment, was not altogether illogical because I
had long recognized that money, greed and power motivated much of the
madness that made human beings war against each other.

25. Renunciation first entered my consciousness when I was
quite young, probably less than ten years old, during a period
I attended Sunday School or Sunday services at the Anglican
Church in Chilliwack, British Columbia, Canada where I was born
and raised. An essential message of the Christian Gospel, which
I learned during that period of my life, is the storing up of
treasure, not in the world where it can be stolen, lost or
destroyed, but in Heaven where it is kept safe eternally. My
earliest recollection of a specific teaching on the subject,
and one which has stayed with me throughout my life, is the
story of the rich young man, reported in Matthew, Mark and
Luke. The King James Bible, Chapter 19 of the Gospel According
to St. Matthew, a copy of which is appended hereto as Exhibit
O, contains the following passage:

"And, behold, one came and said unto [Jesus], Good Master,
what good thing shall I do, that I may have eternal life?

And he said unto him, Why callest thou me good? There is none
good but one, that is, God: but if thou wilt enter into life,
keep the commandments.

He saith unto him, Which? Jesus said, Thou shalt do no murder,
Thou shalt not commit adultery, Thou shalt not steal, Thou
shalt not bear false witness,

Honour thy father and thy mother: and, Thou shalt love thy
neighbour as thyself.

The young man saith unto him, All these things have I kept
from my youth up: what lack I yet?

Jesus said unto him, If thou wilt be perfect, go and sell that
thou hast, and give to the poor, and thou shalt have treasure
in heaven: and come and follow me.

But when the young man heard that saying, he went away
sorrowful: for he had great possessions.

Then said Jesus unto his disciples, Verily I say unto you,
That a rich man shall hardly enter into the kingdom of heaven.

And again I say unto you, It is easier for a camel to go
through the eye of a needle, than for a rich man to enter into
the kingdom of God.

When his disciples heard it they were exceedingly amazed,
saying, Who then can be saved?

But Jesus beheld them, and said, unto them, With men this is
impossible; but with God all things are possible.

Then answered Peter and said unto him, Behold, we have
forsaken all, and followed thee; what shall we have therefore?

And Jesus said unto them, Verily I say unto you, That ye which
have followed me, in the regeneration when the Son of man shall
sit in the throne of his glory, ye also shall sit upon twelve
thrones, judging the twelve tribes of Israel.

And every one that hath forsaken houses, or brethren, or
sisters, or father, or mother, or wife, or children, or lands,
for my name's sake shall receive an hundredfold, and shall
inherit everlasting life.

But many that are first shall be last; and the last shall be
first." Ex. O, Matthew, 19, 16 - 30.

It was not until some time in 1983, more than a year after
leaving the organization that I began to understand the wisdom
of these words, and only in August, 1990 that I was led to
follow them.

26. During my years inside the Scientology organization I was
subjected to L. Ron Hubbard's very different philosophy and
practices concerning treasure, value and his brand of ethics.
In the few times he mentions God in his writings, Hubbard
attempted to mock Him, and he ridiculed the thought of Heaven.
In his "upper level" secret directives Hubbard wrote that
Christ is an implant, a Scientology term meaning a fixed idea
electronically installed by force and pain to control and
suppress its human victim. In exchange for money paid for his
pricey psychotherapy Hubbard promised the worldly treasures of
increased IQ, better communication skills, power, physical
health, and the ability to make even more money. Unable to
deliver on these secular promises, however, Hubbard and his
organization, in response to the thousands of people who have
been defrauded and requested refunds pursuant to his
"money-back guarantees," have employed an army of lawyers to
con our courts with the idea that these representations are
"religious" and the ill-gotten and often extorted payments
"donations." Hubbard stated as his organization's financial
States Tax Court thought this policy so noteworthy it quoted it
in its official reports in Church of Scientology of California
v. Commissioner of Internal Revenue, 83 TC 381 (1984) at 422.
Hubbard and his organization justified their uncharitable
policies and nature with a concept he called "rewarding
downstats," which meant that the unable, infirm and poor should
not be helped because helping such persons only rewarded them
for being unable, infirm or poor. A related Hubbardian "truth"
which permeated the organization was that people "pull in" the
bad things which happen to them; that is, they bring upon
themselves, or deserve, their difficulties or tragedies. This
concept is used not only to excuse Hubbard and his
organization's disregard for human suffering in all its forms,
but to extol the suffering they have heaped on their "enemies."
The attack on, for example, writer Paulette Cooper to ruin the
woman (the organization's intelligence bureau under Hubbard's
direction, in a scheme called "Operation Freakout," which had
as its stated purpose to either get her imprisoned or driven
insane, obtained through trickery her fingerprints on sheets of
paper which were then used to send "anonymous" bomb threats to
political figures) was right, "pro-survival" and ethical,
because Ms. Cooper pulled it in. While this idea supports the
Scientological group psyche in its organization, and in the
entity it presents as plaintiff and defendant in our courts,
its policy, philosophy and psychology do not allow the
application of the same idea to L. Ron Hubbard or to the power
structure that replaced him after his death in January, 1986.
It is forbidden inside the organization even to think a
critical thought about Hubbard or Scientology, and grounds to
be declared "fair game" to expound either the idea that perhaps
he may have done something to pull in some of the names he's
been called; e.g., bigamist, bully, charlatan, cheat, liar,
megalomaniac, swindler, wife beater; or that just maybe some of
the persons the organization attacks do not deserve it. This
double and twisted standard that Hubbard implanted in the
Scientological mind keeps the organization's employees and
customers ignorant of wisdom and blind to the madness of their
actions, words and appearance. But reasonable and rational
non-Scientologists are not blind to these things, as shown
herein in the Breckenridge decision (Ex. B) and the Ideman
declaration (Ex. F). Hubbard was shrewd enough to understand
that even to the brainwashed a persona of "egoism, greed [and]
avarice" (Ex. B, p.9, l.2) would trigger rejection; thus in
public and in the legal arena he applauded his generosity and
flatly denied the suggestion of inurement, In a public
relations piece that went to every Scientologist in the world,
and to any non-Scientologist who wanted one and many who
didn't, he wrote that for all his work in saving mankind he was
paid less than an average organization staff member. I was an
average staff member during this assertion's international
dissemination and I was paid between $4.30 and $17.20 per week.
Hubbard paid himself untold millions. He had complete control
of the organization and all organization bank accounts, and
concocted amazing schemes for international money laundering;
all while having his organization's personnel swear in civil
litigation, criminal cases and official investigations that he
had resigned as Scientology's director in 1966 and from that
date had played no part in the organization's management. In
keeping with his secret affirmations that "all men are my
slaves," and "I have the right to use men's minds as I please,"
by which he programmed himself in the early days of his
"development" of Dianetics and Scientology, he kept his workers
impoverished while he ripped off millions illegally from the
"charitable" corporations in which they labored. The new power
structure has embarked on a glossy PR campaign in which it
laments that all Scientology services aren't free and that it
needs to charge what it does to "help create a safe and
pleasant environment for everyone." A more accurate statement
of the organization's fiscal philosophy is the article in the
May 6, 1991 Time magazine, on the cover of which over an
erupting octopodous monstrosity is blazoned "Scientology - Cult
of Greed." I know personally a great number of people who have
been victimized, abused, ripped off and discarded for no other
reason than to satisfy the power structure's avariciousness. It
is my knowledge of this cult of greed and the threat its
leaders think I am to their shaky house of fraud that has
brought them and their attorneys to attack me so relentlessly.
I acknowledge that it is possible to view the giving away of my
possessions in 1990 as a reaction to the years of inculcation
with Hubbardian greed and meanspiritedness; but I do not see it
that way. Hubbard and his organization were never able to
destroy in me my God-given nature. Even inside the
organization, in circumstances which made charity, compassion
and understanding dangerous activities, Hubbard and his
enforcers were never able to achieve total suppression. They
were not successful with me, and I believe it will be
ultimately shown that they will not have been successful with
anyone; nor is suppression of anyone by any regime, state or
entity entirely successful. It is our God-given nature that
brought every person into Scientology and the Sea Org, and
willing to live, work, fight for a cause, and endure terrible
abuse, without thought of profit, bank accounts, investments or
retiring. In his abuse of that divine nature Hubbard proclaimed
it a "high crime" to even discuss retiring with one's fellow
Scientologist workers. My analysis is that the use of our
highest nature by an individual or organization for purposes
not in our best interest; that is to say, suppression, is not
merely not religion, it is irreligion; and as irreligion it
should be stood up to and seen for what it is. My position in
the litigation is that, by justice, law, this country's
constitution, and God's Will, I am free to communicate that
analysis in all the ways it can be said and by any means and
media there are to say it.

27. I have considered myself a professional artist and writer
since 1984. In the fall of that year organization operatives
broke into the trunk of my car and stole a book manuscript with
original art I then valued at $50,000.00. I demanded my things
returned to me but the organization denied possessing them. I
have recently been advised by former organization executive
Vicki Aznaran that during a time when she was involved
organizationally with its present leader David Miscavige in
operations against "enemies," he acknowledged the
organization's theft of my manuscript and scoffed at my work's
literature. Also in the fall of 1984 the "Armstrong Operation,"
in which the organization had used one of its covert agents,
Los Angeles spy story writer Dan Sherman, to get close to me to
set me up in a number of situations, culminated in my being
videotaped in conversations with two other organization agents,
David Kluge and Mike Rinder. At the end of 1984 I split up with
my wife Jocelyn, who had escaped with me from the organization
in December, 1981, and in early 1985 I travelled to Portland,
Oregon for the trial of Julie Christofferson v. Scientology,
Multnomah County, Oregon Circuit Court, Case No. A7704-05814.
During my cross-examination at the trial in April, 1985, the
Armstrong Operation videotapes and the fact that Sherman, Kluge
and Rinder, who had been presenting themselves as my friends,
afraid for their lives, and seeking my help to reform the
organization's criminal nature, were actually covert operatives
intent on destroying me, were "introduced" by organization
lawyer, Earle Cooley. In September, 1985 I moved to Boston and
worked at the Flynn, Joyce & Sheridan law firm until the
December, 1986 settlement. The organization continued to run
operations against me during this period, I continued to write
and draw, allowed God to work on my mind and heart, and in 1986
founded a church.

28. In January, 1987 I moved to Oakland, California, and then
purchased a home in the Berkeley-Oakland hills where I lived
until 1989 when I purchased a new home in the same hills.
During this period I wrote and drew and followed what I prayed
was guidance. I set up and worked out of an office, on the
urging of Michael Walton incorporated TGAC, started running and
helped whomever I could. Although I knew the organization still
viewed me as an enemy and had attacked me in various ways after
the settlement I did not become substantially reinvolved with
it in the legal arena until the fall of 1989 and spent
virtually no time until then on organization-related matters. I
became an accredited Teacher of God during this period, and
also was given my first glimpse of the resolution of the
economic problems facing the world. This glimpse, which I wrote
into an essay entitled "A Crash Course in Speculation," a copy
of which is appended hereto as Exhibit P, was a step toward my
renunciation, which itself is, I believe, an incident of
planetary salvation. My reinvolvement with Scientology is
described in my declaration of March 15, 1990 (Ex. G hereto),
my declaration of December 25, 1990, a copy of which is
appended hereto as Exhibit Q, and in the boxes of documents
filed in the four Armstrong cases. I filed the December 25,
1990 declaration as an appendix to a response brief in the
appeal (B 038975) of the order unsealing the Armstrong I court
file for Bent Corydon.

29. I first met attorney Michael Walton in about April 1982,
shortly after we both began working at the law firm of
Feldsott, Lee and Van Gemert in Newport Beach, California. We
became friends and stayed friends when I left southern
California, moved to Portland, Boston and the Berkeley-Oakland
hills. We spent many hours together through those years and
talked for many hours about many things, including my art,
writings, inventions and philosophic ideas, and we considered
doing various projects together involving these products or
ideas. Mr. Walton was familiar with my Scientology history and
litigation, the organization had taken his deposition in
Armstrong I, claiming it was needed because he was for some
matters my administrative senior in the Feldsott firm, and he
attended several days of my trial in 1984. He has represented
me in literary and legal matters and I have consulted with him
on a number of occasions since that time. Before becoming a
lawyer he taught English in university, he is a writer, and for
a period of time before the December, 1986 settlement,
considered writing a book himself about Hubbard.

30. One of the things I did with the money I was given in
settlement of Armstrong I was to form a partnership with
Fairfax architects Rushton-Chartak and San Anselmo builders
Grizzly Hill Construction to purchase a rare piece of property
at 707 Fawn Drive in the unincorporated land of Marin County
and build thereon a spec house, hereinafter "Fawn." I provided
the initial capital, the work was done and the house completed
toward the end of 1989. At the same time an unusual phenomenon
in the California half-million-or-so dollar house market
occurred; it dried up and crashed. For me all of a sudden it
made economic sense to buy Fawn myself. When that idea arose,
the idea of hooking up with Mr. Walton and doing some of our
often-discussed projects together also arose, and fairly
naturally, because he had been thinking about leaving the south
and Fawn was a reasonably big house which could sensibly
contain his law office, my business, our respective companions
and his one-year old son. We arrived at an arrangement which
worked for both of us, I sold my East Bay house, and the five
of us moved into Fawn in May, 1990. I made the down payment for
the Fawn purchase and put enough cash into a joint checking
account to cover a year's mortgage and utilities payments.
Although to a Scientologist, the organization's lawyers or
other similarly hard-nosed business persons it can certainly be
argued that I put more than my share of capital into Mr.
Walton's and my venture, in which it would also be mainly my
creations or ideas which would be commercially developed, and
that there is therefore something wrong, suspicious or even
fraudulent in so doing, to me these actions rather reflect
rightness and probity. I was dedicated to my work being God's
and to doing some creative projects with Mr. Walton, I had
generally had a something different from ungenerous nature, and
I knew, as expressed in my 1989 essay "A Crash Course in
Speculation," that money has no value. Renunciation has, of
course, greatly reduced my numismatic largess.

31. Within a month or so of the move into Fawn, Mr. Walton's
friend Jody and their son Dylan moved out, we got our offices
functioning and spent a lot of time getting the house and yard
functioning. I ran, and with my helpmeet Lorien Phippeny
developed into demonstrated workability a program to have the
world's runners clean the planet of its street litter. I joined
a running club and bought a mountain bike. Before the move to
Marin County Mr. Walton had already agreed to represent me in
the organization's appeal (B 025920) from the Breckenridge
decision, permission to respond in which I had already obtained
from the Court of Appeal in February, 1990, and we filed a
Respondent's Brief on July 9, 1990.

32. Also in February, 1990 I received an invitation from the
IRS to discuss my 1987 tax return. The discussion did occur,
the IRS issued an Information Document Request, and I responded
on April 24 with a book which I have given the working title
Auditing Gerald Armstrong. A copy of the manuscript along with
its supporting documents, except for those which are already
exhibits to this declaration, is appended hereto as Exhibit R.
This complete book was produced by me on March 10, 1993 in
attorney Wilson's office pursuant to the organization's request
for production in Armstrong II. He and the organization were
therefore aware of the following facts from the Auditing GA
manuscript before they filed the Armstrong IV complaint:

A. That I had written "A Crash Course in Speculation;"

B. That in July, 1987 I had offered to the captors then
holding several hostages in Lebanon my house, and for that
matter my life, without monetary consideration, and for reasons
unrelated to the organization;

C. That in the summer, 1989 edition of Common Ground I had
offered my philotherapeutic sessions at no cost;

D. That Nancy Rodes had declared under penalty of perjury on
November 28, 1989 that she knew me to be a religious figure and
had been my hagiographer since 1984; and,

E. That TGAC has never existed solely so that I may be
"judgment proof."

33. Even though I was aware of Jesus's admonition to his
disciples to not be troubled by wars and rumors of wars (Mark
13, 7; Luke 21,9), I was undeniably affected by the media
images of Desert Shield as it built into Desert Storm and the
international diplomatic drama that accompanied the military
operations. I had already been moved, I felt, to enter the
political and sociological landscapes, as I believe is shown by
the letter to the captors, "Crash Course" and their recipients
lists. I had also considered and argued in these other
political matters - the hostages, the economy - that something
could be done about them, and that what I thought could be done
was, at least on paper, a better idea. It was not out of the
ordinary or out of character, therefore, for me to consider
that I could do something about Desert Shield, Desert Storm or
the whole blessed Middle East. It was at that time that the
idea came to me to give away my worldly possessions and to give
myself to the cause of peace. After some thought, I transferred
my interest in Fawn to Mr. Walton, divided my one hundred
percent ownership of TGAC equally between my friends Nancy
Rodes, Michael Douglas, Lorien and Mr. Walton, and forgave all
debts owed to me. I knew by this time that our Source is also
the source of everything, including money, and that He would
provide for me all that I would need to carry out His work. I
also was fully aware that I was engaged with the organization
on the legal battlefield, and although I was confident of the
outcome, I had no idea what would happen on the road toward
that day. I recognized that the organization's ruling clique
was motivated by the same forces of money, greed and power that
made men war against each other and that my renunciation was
spiritually directed at bringing peace for the organization no
less than the rest of the world. And, as I stated above, I
accepted the fact that should my legal battle with the
organization continue I would more likely than conceivably
litigate indeed in forma pauperis. I communicated my decisions
to everyone directly affected by them, took care of the
paperwork needed to make the decisions legally effective, and
tied up various loose ends. It became clear to me that the
renunciation had left me unattached and free to travel wherever
I was called should I be. I gave my car to Lorien, but she
returned it, and we took a trip together during September
through the western states and British Columbia to develop a
sociological concept that had come to me. When we returned to
California Lorien moved to Santa Cruz and I, not then being
called to go elsewhere, stayed at Fawn where I worked on some
house and grounds projects, continued to maintain TGAC's
office, and kept picking up trash. I also came up with what I
thought was a good plan for resolving the Middle East crisis
and I communicated this plan to various media and certain
leaders or envoys I thought were in positions to do something
about it. In my letter to Saddam Hussein of November 1, 1990 I
offered, as I had with the Lebanese captors in 1987, to
exchange myself for the hostages then being held in Iraq; but I
did not sweeten the deal with my interest in a house, as I had
done in the earlier offer, because I had already conveyed it to Mr.
Walton. Copies of this letter, my November 7, 1990 letter and
list of addressees to which they went, my December 10, 1990 and
January 10, 1991 letters are appended hereto as Exhibit S.

34. On December 28, 1990 I filed a response brief and appendix
(Ex. Q hereto) in the B 038975 appeal (see paras. 14 and 28
above). On December 31, Mr. Walton married Solina Behbehani,
and she and her teenage son Sephy moved into Fawn. Oral
argument in the two appeals, B 025920 and B 038975, was heard
on February 20, 1991. At some point during the months following
my renunciation it became clear to me that I would go in the
world wherever my help was asked for, and, as much as was
sensibly safe, courteous and wise, provide my help without
monetary remuneration. Initially only Mr. Walton asked for my
help so I had no reason to leave Fawn. Then Nancy Rodes asked
me to help her complete and clean a house she had built in the
Oakland hills, which I did through the spring of 1991. This
worked well because she was broke and I worked for free. I
returned to Fawn for a couple of weeks to complete a painting
project I'd started earlier, then traveled to British Columbia
for my parents' fiftieth wedding anniversary. While in B.C. I
received a call from Malcolm Nothling in Johannesburg, South
Africa who asked for my help in a lawsuit he had brought
against the organization which was then set for trial in
August. He said he had not been able to find anyone else in the
world willing to testify about the organization's policies and
practices. Having already put the organization on notice in
February, 1990 that I considered the restrictions of the
settlement agreement unenforceable, and after listening to Mr.
Nothling's story, and because he asked, I agreed to help him. I
told him, however, that I wanted first to see if his situation
could be resolved peacefully without the hatred and waste which
seem to be the hallmarks of the organization's legal
confrontations. A copy of my effort, a letter to attorney Eric
Lieberman, who represented the organization in the Armstrong I
appeal and in many of its appellate matters, is appended hereto
as Exhibit T. Mr. Lieberman sent me a letter rejecting my peace
proposal, I flew to Johannesburg and helped Mr. Nothling, but
did not testify because the organization was able to obtain a
postponement of the trial.

35. Soon after my arrival back from Canada and just before
leaving for Johannesburg I got a call from attorney Joseph
Yanny, who'd become a good friend over the previous year or
more, and who had come into the case of Richard and Vicki
Aznaran v. Scientology, US District Court for the Central
District of California case no. CV-88-1786-JMI, after the
Aznarans were tricked by the organization into firing their
lawyer of more than two years, Ford Greene. The organization
had immediately filed a mountain of summary judgment and other
motions. Mr. Yanny said he needed my help. I traveled to Los
Angeles in the few days I had before I was scheduled to fly to
South Africa, on July 16 wrote a declaration, a copy of which
is appended hereto as Exhibit U, concerning the effect of the
1986 "global settlement" on litigants against the organization
and in the legal community, and generally helped out in the
moral support department. Mr. Yanny is a member of my church
and we have talked many times over the past few years on
matters of the soul.

36. As I was leaving for South Africa I learned from Mr. Yanny
that the organization had sued him for allegedly inducing me to
breach the settlement agreement. In response to that charge,
between planes in New York I wrote a declaration dated July 19,
1991, a copy of which is appended hereto as Exhibit V, in which
I stated my philosophy regarding my calling to help.

"But more than a desire to protect myself or right the
organization's unjust acts towards me, however, I helped Mr.
Yanny for the simple reason that he asked. I will do the same
for anyone....It is not only the right of all men to respond to
requests for help, it is our essence. If I was induced,
therefore, to help Mr. Yanny, or anyone else, it was our
Creator Who induced me."

The organization's lawsuit against Mr. Yanny actually claimed
that he was representing me in Scientology-related litigation,
which was, the organization also claimed, since he had for a
period of time represented it in various matters, a breach of
his continuing duty to it. Although I had consulted Mr. Yanny
regarding some of my literary and artistic products and ideas,
he had never represented me in any litigation and I had never
consulted him about my organization legal battle. The
organization's allegation that he represented me had no basis
in fact and the complaint was dismissed.

37. While I was in South Africa the California Court of Appeal
on July 29, 1991 affirmed the Breckenridge decision, and I
learned that Judge Ideman in the US District Court had
reinstated Ford Greene as counsel for the Aznarans. When I
arrived back in the US I returned to Fawn and a day or so later
dropped by Mr. Greene's office, which, as Heaven would have it,
is maybe two and a half miles away in uptown San Anselmo. It
became instantly clear that Mr. Greene, in a very tangible way,
as much as anyone else in the world, really did need my help.
He faced the Everest of motions, which the organization had
filed when the Aznarans were lawyerless, with no time, no
staff, no sleep, little organization, hopelessly in debt,
hounded by creditors, his own car held by a creditor garage.
Again I achieved near perfect economic symbiosis: he had no
money and I worked for free. To render it a truly irrefusable
deal, I had wheels. I knew my way around a law office, had
something of a history of document assembly, could run a
photocopier, stapler and hole punch, answer a phone, and had an
adequate command of the Canadian language. I was blessed with
an understanding of the cultic manufacturers of the paper
mountains that threatened to crush Mr. Greene, his office, and
the Aznarans along with them. And I recognized that Mr. Greene,
in spite of whatever had brought him to the point of
desperation where he truly needed my kind of help, had a really
good mind and heart, a unique talent, was, as I had begun to
see we are, guided, and with great luck and hard work might
survive. So I've been working with him, as his sole office
support, since August 15, 1991. We have both survived, worked
hard, taken a few hits, and Mr. Greene can now afford to pay me
something and does. When things were really lean some other
good friends have loaned me money, TGAC sold a couple of shares
to still others, and always money has arrived, as God would
have it, in His unmistakably mysterious ways. Mr. Greene has
successfully defended me in the four cases the organization
maintains against me and has helped me as I have helped him.

38. Immediately upon my return from South Africa I received a
copy of a lawsuit the organization had filed August 12, 1991
against seventeen named United States agents, Church of
Scientology International v. Xanthos, et al., US District Court
for the Central District of California, No. CV-91-4301 SVW(Tx).
Included in the complaint, a copy of which is appended hereto
as Exhibit W, was the allegation that:

"The infiltration of the Church was planned as an undercover
operation by the LA CID (Criminal Investigation Division of the
IRS) along with former Church member Gerald Armstrong, who
planned to seed church files with forged documents which the
IRS could seize in a raid. The CID actually planned to assist
Armstrong in taking over the Church of Scientology hierarchy
which would then turn over all Church documents to the IRS for
their investigation." (Ex. W. P. 14, l. 3) Although I had seen
this organization attack line in many forms and venues since
1985, this 1991 charge signaled to me that the organization was
not about to peacefully end its legal and psychological war in
which I was one of its most hated enemies. In recognition of
that fact as well as logistical reasons I moved out of Fawn and
into Mr. Greene's law office at the same time as I started
working with him. Mr. Walton and I had already picked up
organization surveillance at Fawn, his stepson Sephy was very
troubled by the threat he perceived, everyone in the house felt
threatened to some degree by the organization, and I did not
want to bring any danger to this family, who were my dear
friends and completely uninvolved with my Scientology conflict.

39. When I began working with Mr. Greene I almost immediately
picked up surveillance, and very shortly thereafter the
organization began to attack with declarations and motions
filed in the Aznaran case, accusing me of violating various
court orders, illegal activities and acting as Mr. Yanny's
covert agent in Mr. Greene's office. In response to this paper
onslaught, on September 3, 1991 I wrote a declaration, a copy
of which is appended hereto as Exhibit X, which was filed by
Mr. Greene in Aznaran.

40. On October 3, 1991 the organization filed a motion in
Armstrong I to enforce the settlement agreement, I opposed, and
on December 23 at a hearing where I was represented by attorney
Toby Plevin, Los Angeles Superior Court Judge Bruce R.
Geernaert denied the motion. Judge Geernaert was familiar with
the case, having inherited it after Judge Breckenridge's
retirement and having unsealed the file on Bent Corydon's
motion. On February 4, 1992 the organization filed Armstrong II
in Marin County and on March 20 it was transferred to Los
Angeles Superior Court. The organization brought a motion to
enjoin me from violating the settlement and on May 28, 1992
Judge Ronald M. Sohigian entered a partial injunction, a copy
of which is appended hereto as Exhibit Y, prohibiting me from
assisting litigant claimants against the organization, but
refusing to prohibit me from doing anything else the
organization might consider settlement agreement violations. I
filed an appeal from the Sohigian injunction, Scientology v.
Armstrong, No. B 069450 in the California Court of Appeal,
Second Appellate District, Division Four. At this date the
appeal has been fully briefed and is awaiting the scheduling of
oral argument.

41. In October, 1992, stirred by the imminent national
election, I came up with a plan for initiating the peaceful
transformation of the nation's, and the world's, economic
system through the Organization of United Renunciants,
hereinafter "OUR," which I had conceived of and founded some
time earlier. I wrote a series of short essays on the plan and
the thought underlying it and sent a pack of these materials to
several political and media persons. A copy of OUR basic pack,
including the list of its initial recipients, is appended
hereto as Exhibit Z. In one of the essays entitled "OUR
Deadline" I write:

"George Bush's deadly deadline to Saddam Hussein gave me the
idea of issuing OUR deadline. The fact that it was OUR deadline
resulted in the Organization of United Renunciants. Organizing
renunciants made sense because I had, in August 1990, as a
result of understanding the Persian Gulf crisis, and accepting
the idea of renunciation as guidance, given away all my money,
real estate, paper holdings and personal effects and forgiven
all debts owed me."

42. On November 11, 1992 the Marin Independent Journal
published an article entitled "Is money the root of problems?
Critic of cash, credit urges monetary abolition," a copy of
which is appended hereto as Exhibit AA, dealing in manifestly
good humor with my economic idea and OUR plan for its
implementation. IJ reporter Richard Polito writes:

"Fellow renunciants will renounce all cash and credit, stop
taking money, forgive all their debts and stop keeping
financial records.

The critic of credit has already put his money where his
doubts are. He gave it all away. And it was more than pocket

Armstrong won an $800,000 settlement in a harassment suit
against the Church of Scientology six years ago." (Ex. AA)

43. Because the Nothling case was set to go to trial in
February, 1993, on December 22, 1992 I again wrote to the
organization to see if a communication from me could initiate a
peace process. A copy of my letter, addressed to David
Miscavige, the person who in every sense can order anything
within the organization or its corporate, financial or legal
affairs anywhere in the world and enforce compliance with all
such orders, is attached hereto as Exhibit BB. I sent copies of
the letter to an extensive list of people I thought should be
apprised of its content. Having been accused by the
organization so stridently for more than a year of "fomenting
litigation" against it, I made a special point and, I think, an
honest effort, in this letter, and in my other communications,
to unfoment its litigation. I include in the letter a statement
of an aspect of my belief, which, I believe, is central to
understanding the organization's conflict with me.

"I believe that everyone will become a person of good will,
that everyone already is, has been and will forever be, that
there is progress and perfection, hope and reason, that to know
who we are we must accept the truth of our relationship to our
Creator, that all about us that we made is illusion, that we
have reason to be grateful that is so, that our Creator, God,
our Father Loves us in the same Love by which He created us and
holds us always safe and always loved in that Love, that we,
His children, are one and One with Him, that the means by which
He is remembered, and hence our relationship, and hence who we
are, and hence what we know, is forgiveness, that forgiveness
is the recognizing of illusion for what it is, that creation is
our nature, and that everything is all there is." (Ex. BB, p.

The organization appears in its statements and efforts to view
me as competition in what it claims as its niche, which it
calls "applied religious philosophy," in what it apparently
perceives as the salvation market. Appended hereto as Exhibit
CC, for example is a copy of an organization directive in which
I am labelled a "squirrel," a hate word the organization uses
for people it considers its competition. Hence it seeks to
destroy my reputation and resorts to outrageous legal
shenanigans to have me judicially silenced. In truth, although
some of what I say or do could be construed as applied
religious philosophy, I have never used this description. I do
not compete with Scientology for anything, and certainly not
for its paying customers. I promote the philosophy that
salvation is free, and the organization promotes a philosophy
that says that the only workable means of salvation costs a
certain, and generally escalating, quantity of money, or, for
its employees, a certain number of years of labor, and that the
organization possesses and owns said only workable means and
the only workable delivery system. My philosophy is owned by
everyone, and the living God is its Source, as He is of
everything. Scientology proclaims that its deceased leader L.
Ron Hubbard is salvation's source. I neither sell nor use the
organization's philosophy and my delivery system is different
in every way from the organization's. If people want to pay for
salvation and take something not indistinguishable from a
significant amount of time getting saved they can go to
Scientology. Those who want immediate salvation without any
sacrifice or cost whatsoever can come to me. The organization
does not even accept as customers anyone who believes that
salvation is available right now without sacrifice, so I am in
no way a competitor. The organization banks on the idea that
there are people who want to pay money for salvation, so it
promotes to that paying public. I bank on the idea that we're
already saved, so for Heaven's sake don't spend good money on
it. Since I am not looking for anyone who wants to pay for
salvation, and do not even consider that if someone feels he
wants to pay for it I have something to sell him, I truly am
not in competition with the organization. There are,
admittedly, probably more people who want salvation to be free
than there are who want to pay for it, but that is just the way
Providence has dealt out preferences for freedom versus cost.
Also admittedly, in a strictly business sense, my philosophy
has another undeniable advantage because in this world everyone
can afford the salvation I offer; whereas those who can afford
Scientology's road to salvation, without even taking into
account the desire to devote the time the organization says is
required, are considerably fewer in number. But the
organization enjoys certain advantages as well because of its
administrative structure and technology; for example, its
policy prohibiting its customers from mixing practices. Once
people become Scientology's customers the organization will not
permit any to come to me to be saved and continue on its
salvation program, what it calls the "bridge to total freedom."
In fact the persons I had saved would not even be allowed to
continue to hang out with their Scientologist friends, and
those Scientologists would be prohibited from hanging out with
their former friends once I've saved them. Those kinds of
prohibition wouldn't work well in my delivery system, so anyone
I save is at liberty to jump ship and take up Scientology's
cross, and still, as far as I and my philosophy are concerned,
hang out with me or anyone else in the world. This does not put
a great strain on me, it's true, because in my system, as
stated above, salvation doesn't take time, nor does it have to
be repeated. There is, of course, the matter of the other
people the organization also rejects and refuses to save even
if they could afford the program; for example, drug users, the
mentally ill, convicted felons, present criminals, shock
victims, critics, people declared suppressive persons, and
people connected to people declared suppressive persons.
Thus there may be some crossovers, but it is silly of the
organization to complain because I save those souls it rejects.
By its Suppressive Person Declares in 1982 (see, Ex. C, p.
920), the settlement agreement in 1986 (Ex. D), and its
lawsuits to enforce the agreement up to present time, the
organization has sought to prevent me from having access to
its means of salvation and delivery system. The settlement
agreement required that I "never again seek or obtain spiritual
counselling or training or any other service from any Church of
Scientology, Scientologist, Dianetics or Scientology auditor,
Scientology minister, Mission of Scientology, Scientology
organization or Scientology affiliated organization." (Ex.D at
p. 10)

If persons are rejected by Scientology because they had a
criminal conviction, took LSD, testified truthfully in
organization litigation, are crazy, or were, as I had been,
declared a suppressive person, and such persons still want
salvation, they can come to me. I save everyone and believe
there is nothing anyone can do to prevent his being saved. I
simply do it for free, whereas the organization charges its
customers to do it to them. Clearly, Scientology has its public
and its market and I have mine. I do not advertise to those who
want to pay for salvation so there is no way I can possibly
threaten the organization's customer pool. In fact I don't
advertise even to those who want salvation at no cost, but
simply trust that God will lead to me, without charge, those
people I am to save. If Scientology moved into my field and
started saving people without cost of any kind, it would
conceivably have a reason to view me as competition and
consequently would have an excuse to ruin my reputation and
have me judicially restrained from practicing my profession. I
think that if the organization really were to move into my
technological field, however, it would see that it's wide open
and there are more than plenty of customers who don't want to
pay for salvation, can't, or both, to go around. I tried the
organization's philosophy for a significant number of years,
and because I am intellectually sound, observant, trained in
wisdom, and willing to talk and testify about my observations
and can form reasoned opinions thereon, I am, in the litigation
world, an expert therein. It goes without saying that when lots
of people are willing to talk about their organizational
observations I will cease to be considered an expert. But even
until that day dawns, although I am an expert in what the
organization sells as its means to salvation, I am not in
competition with it. There is no reason for it to feel
threatened by my beliefs or my salvatory methodology, and no
reason for it to vilify me or work so assiduously to get some
court to silence me. I follow the system perfected by Jesus
Christ which is not even in competition with nothing or no one.

44. On December 31, 1992 the organization filed an ex parte
application in Armstrong II for an order to have me held in
contempt of court. The application and the supporting
declaration of attorney Bartilson, along with the exhibits
thereto, except those which are already exhibits to this
declaration, are appended hereto as Exhibit DD. Exhibit G to
the Bartilson declaration is my December 22 letter to David
Miscavige (Exhibit BB hereto), and exhibit R is a copy of the
November 11 Marin Independent Journal article (Exhibit AA
hereto). Ms. Bartilson also attaches to her declaration a few
excerpts from my depositions, correspondence from Ford Greene
regarding three of his clients, Tillie Good, Denise Cantin,
D.O. and Ed Roberts, all of whom had claims against the
organization for refunds of money extorted from them, the
transcript of a video interview I did in November, 1992, and
two proofs of service I signed in the Aznaran case. Ms.
Bartilson charges that these things add up to six violations of
the Sohigian injunction and that for each of said violations I
should be fined and jailed. In her application, citing to the
Independent Journal article, Ms. Bartilson argues:

"The Court should exercise all of its available powers to
impress upon Armstrong that its orders mean what they say and
will be enforced, despite the intransigence of an enjoined
party. Indeed, incarceration is an unusually viable vehicle for
impressing upon Armstrong the import of his obligations,
inasmuch as Armstrong has publicly disavowed money as a
meaningful commodity." (Ex. BB, Memorandum p. 13) Although in
Armstrong II the organization used my renunciation to support
its effort to have me jailed, in Armstrong IV the organization
omits any mention of renunciation, claiming instead that my
giving away of my assets were fraudulent conveyances to render
me judgment proof, and that in fact I still owned and
controlled those assets, and was presumably rolling, albeit
quietly, in dough. The organization is in error in both of its
scenarios. My conveyances were not fraudulent, and because I
may have disavowed money is no reason I should be incarcerated.

45. Appended hereto as Exhibit EE is a copy of my declaration
dated February 2, 1993 and the exhibits thereto which I wrote
in response to Ms. Bartilson's December 31, 1992 declaration
and application for the order to show cause re contempt (Ex. DD
hereto). Exhibit F to my declaration and described therein at
page 24 is a page from the organization's November 1992 edition
of its publication "Membership News," which it uses to attack
the Cult Awareness Network, hereinafter CAN, an organization
which educates the public about destructive cults including
Scientology and provides support to families broken apart or
hurt by such destructive cults. Although the article is only a
common, Scientologically standard, fair game, bald-faced, Black
PR smear of CAN and me, it again shows the organization's
recognition of my monetary philosophy and renunciation.

"Armstrong has some odd financial ideas. He is the
self-proclaimed founder of the 'Organization of United
Renuniciants.' In November 1992, the Marin Independent Journal
attempted to explain Armstrong's philosophy of life in an
article 'Is money the root of all problems?'" (Ex. F to Ex. EE

My February 2 declaration was not filed in Armstrong II because
Mr. Greene felt the organization's effort to have me held in
contempt could be defeated without my testimony. I did file a
declaration, a copy of which is appended hereto as Exhibit FF,
executed on February 11, 1993 by former organization covert
operative Garry Scarff. Mr. Scarff had been involved in
operations against Mr. Greene and me with the organization's
head private investigator, Eugene Ingram, indentified in
paragraph 15 above.

46. On March 5, 1993 at a hearing on the organization's
contempt attempt, a copy of the transcript of which is appended
hereto as Exhibit GG, Los Angeles Superior Court Judge Diane
Wayne refused to rule because the appeal from the Sohigian
injunction was still pending. She did, however, make a couple
of comments about the injunction's enforceability which, if
nothing else, should be taken to heart by the organization.

"THE COURT: It seems to me ridiculous to hold this hearing
prior to a determination whether or not this is a valid order.
I mean, I have serious questions about the validity of the
order.... (Ex. GG, p. 2)

I'll tell you, when I first looked at this order, I thought
the order was clear until I then read part of the transcript.
Then it became unclear to me. And I think that is in front of
the appellate court, whether or not this is an order capable of
being followed, because Judge Sohigian's comments that at least
confused me a little bit." (Ex. GG, p. 6)

47. On March 22, 1993 LA Superior Court Judge David A.
Horowitz, who presides over Armstrong II for all purposes
except the enforcement of the Sohigian injunction, granted my
motion to stay all proceedings pending a decision in the appeal
of the injunction. In his order, a copy of which is appended
hereto as Exhibit HH, he stated:

"The central issue of this case is the legality and validity
of the [1986 settlement] Agreement. The Court of Appeal could
certainly reach that issue in its determination of the validity
of the injunction. If it does, that ruling could be
determinative of many of the issues of this case. It makes no
sense to proceed with this matter until the Court of Appeal
makes its ruling." (Ex. HH)

48. On March 18, 1993 I made an agreement with Bob Carlson,
the producer of a talk show, "Lifeline," on a Christian
religion radio station, KFAX, in Fremont, California, to be a
guest on the show on April 28. When I arrived at the station on
that date, the host Craig Roberts handed me a fax letter
received a few minutes earlier from Ms. Bartilson, a copy of
which is appended hereto as Exhibit II. In the letter, which is
addressed to me, Ms. Bartilson threatens more litigation if I
did the show.

"Should you appear on this radio show in violation of the
Agreement, the Church of Scientology Internationalwill pursue
all remedies within the judicial system to obtain damages from
the violation and/or to enjoin any future violations of a
similar nature." Mr. Roberts said that because the letter also
threatened the station with litigation should I go on the show,
and because although the station had called its attorney it had
not spoken to him, I would not be on the show. I responded to
Ms. Bartilson on May 3 with a letter, a copy of which is
appended hereto as Exhibit JJ.

49. On June 4 I executed a declaration, a copy of which, along
with the exhibits thereto except for the Breckenridge decision,
is appended hereto as Exhibit KK, in support of a special
motion to strike the complaint in the case of Church of
Scientology of California v. Larry Wollersheim, LA Superior
Court No. BC 074815, hereinafter "Wollersheim II." In 1986
Lawrence Wollersheim had won a thirty million dollar judgment
in the case of Wollersheim v. Scientology, LASC No. C 332027,
hereinafter "Wollersheim I." The organization had appealed and
the Court of Appeal, while castigating Scientology's fair game
doctrine and coercive use of its psychotherapy techniques,
reduced the award to two and a half million (Wollersheim v.
Scientology (1989) 212 Cal. App. 3rd 872; 260 Cal. Rptr. 331.
The organization had taken the judgment up to the US Supreme
Court, back again to the California Court of Appeal, and on a
trip or two to the California Supreme Court. Then on February
16 1993, shortly after the Wollersheim I trial judge Ronald
Swearinger died, the organization filed Wollersheim II, seeking
to have the original judgment set aside by alleging that Judge
Swearinger had been biased against the organization in the 1986
trial. My June 4 declaration focuses on my observations and
knowledge of the organization's litigation practices, which had
clear relevance to what it was trying to do in Wollersheim II.

"Scientology regularly attempts to bludgeon the opposition into
submission with a blizzard of meritless paper, motions,
depositions, appeals, writs, Bar complaints, criminal
complaints, perjured testimony, and other improper and abusive

I am also aware that Scientology uses an attack strategy
against judges who rule against it, which includes claims of
bias and prejudice and frequently personal attacks. For
instance in [Armstrong I], Scientology twice tried
unsuccessfully to disqualify Judge Breckenridge from the case
because of his alleged bias, and levied personal attacks on
him, accusing him publicly of Nazi affiliation. Similarly in
Aznaran ... Scientology unsuccessfully attempted to recuse
Judge James Ideman because of alleged bias." (Ex. II, p. 5)

50. On July 26, 1993, attorney Bartilson filed another
application in Armstrong II with Judge Diane Wayne seeking to
have me held in contempt for providing the declaration to Mr.
Wollersheim. The application and Ms. Bartilson's charging
declaration are appended hereto as Exhibit LL. Ms. Bartilson
supports the application with the same shoddy argument she used
in her December 31, 1992 application, that when I state in my
June 24, 1992 deposition that I have no intention of honoring
the settlement agreement I am talking about the Sohigian
injunction. (Ex. LL, Memorandum p. 2; Ex. BB, Memorandum p. 3,
l. 3; Ex. BB, Bartilson Declaration, p. 2, l. 26; See also Ex.
CC, p. 1, para. 3) She concludes that:

"Gerald Armstrong should be ordered to show cause why he should
not be held in criminal contempt of this Court for his June 4,
1993 declaration, with punishment in the form of a fine not to
exceed $1,000.00 and/or jail time not to exceed five days as
this Court sees fit."

51. Appended hereto as Exhibit MM is a copy of my memorandum
filed September 7 in opposition to Ms. Bartilson's order to
show cause re contempt. Mr. Greene argues in the opposition

"It is clearly discernible that, whatever infirmities intrinsic
to the injunction there are, Armstrong is prohibited from
"voluntarily assisting" persons with claims "against"
Scientology. In other words, Armstrong is prohibited from
assisting private litigant plaintiffs in litigation in which
Scientology is a party." (Ex. MM, p.4, l. 3.)

"For the purpose of the instant application, the only salient
point is that in Wollersheim II, Scientology sued Wollersheim.
Therefore, any assistance provided by Armstrong to Wollersheim
in Wollersheim II is outside the scope of the Sohigian
injunction." (Ex. MM, p. 5, l. 8)

52. Apparently undeterred by Mr. Greene's illumination of the
facts, on September 10 Ms. Bartilson filed a response, a copy
of which is appended hereto as Exhibit NN, defending her effort
to have me found in criminal contempt with the assertion that
because Mr. Wollersheim had been a claimant in Wollersheim II
was prohibited by the Sohigian injunction from assisting him in
Wollersheim II where he is a defendant. She bolsters her
argument with the amazing pronouncement that the 1993 action,
Church of Scientology of California v. Larry Wollersheim, "is
not litigation levelled "against" Larry Wollersheim." (Ex. NN,
p. 3, l. 12).

53. In support of her response to my opposition, Ms. Bartilson
filed a letter dated August 15, 1993, a copy of which is
appended hereto as Exhibit OO, that I wrote to attorney Wilson
in an effort to mitigate damages and initiate a peace process
in the Armstrong IV case. Ms. Bartilson quotes in her response
a funny few sentences from the letter, my riposte to Mr.
Wilson's stab, itself not altogether unhilarious, in Armstrong
IV that "[b]eginning in February, 1990, and continuing unabated
until the present, Armstrong has breached the Agreement..."
(Ex. A, p.7, para. 22) Ms. Bartilson interprets my humor and
letter as something radically different from the way I see them.

"This contemptuous response to the 1986 settlement agreement
(pursuant to which he happily accepted more than $518,000.00)
and this Court's orders are precisely why Armstrong has been
ordered to show cause herein. CSI seeks this Court's help in
demonstrating to Armstrong that he will, indeed, be held
accountable for his wrongful actions, and that they must
cease." (Ex. NN, p. 5, l. 13) Actually my letter contains no
mention of the Sohigian injunction or any other of "this
Court's orders." It does, however, contain another effort to
unfoment the organization's litigations.

"So again, I extend to you and to your client the invitation to
meet with me honestly and openly for the purpose of
communication towards the resolution of our conflicts." (Ex.
OO, p. 5) Mr. Wilson has not answered my letter, and, as it has
done with me for almost twelve years, the organization refuses
to communicate, other than through its barbarous attorneys'
judicial barrages or its covert agents' duplicitous prattle.

54. At a hearing on September 14 Judge Wayne, because the
Court of Appeal had still not ruled in my appeal from the
Sohigian injunction, again refused to entertain the
organization's application to have me held in criminal
contempt, and reset the hearing on the two orders to show cause
for December 6. This hearing has now been continued again to
April 6, 1994.

55. TGAC, defendant in Armstrong II, III and IV, possesses,
cares for and commercially develops my products and is in the
business of peace. Appended hereto as Exhibit PP are pages from
Pacific Bell's Marin yellow pages for 1992 and 1993, wherein
TGAC is listed in the category "peace organizations." TGAC also
provides philosophic services in a number of other areas of
human endeavor and understanding, such as law, religion, health
and economics. It is a unique company with unique, both
banausic and beneficent products. It has not yet become
financially profitable, but I believe that is merely a matter
of time, and I am not unhappy that TGAC's buildup toward
profitablity has taken the form, route and time that it has. It
has also become apparent to me that the litigation in my life
may very well require resolution before TGAC is free to tackle
the problems and projects for which it was created. But no
matter what conspiracy theories the organization and its
lawyers fabricate, TGAC was not created to have anything to do
with it, its litigation or its philosophy. TGAC's founder,
owner, president, manager, senior baker and vice president for
questions and loopholes, just happened to be a person with a
long, intense history with the organization, which has its own
long, intense history. No matter what kind of business I had
gotten into I would have brought with me the same history;
which is now, six years and three more Scientology lawsuits
later, even longer and no less intense. No matter what kind of
business, or enterprise, profession, career or club I had
gotten into the organization would have carried out the same
set of post-settlement fair game sillinesses to keep me
involved with its litigation and its leaders. I happen to have
been given certain talents, knowledge and identity by my
Creator. I am a writer, thinker and artist, and thus my words,
art and ideas exist, and some of them TGAC happens to own and
possess, and, God willing, will develop commercially.

56. When I activated TGAC at the beginning of 1988 I
transferred to the corporation all my writings, artwork, files
and office equipment and supplies that I had previously owned
in my sole proprietorship. At that time I owned all TGAC stock,
TGAC owned all my archive materials, and I had an arrangement
with TGAC whereby my products and acquisitions of an artistic
or literary nature passed to the corporation as I produced or
acquired them. Because the organization had continued to attack
me following the December, 1986 settlement, because I am
connected to many people with an interest in the resolution of
the organization's war on justice and innocence in our society,
and because I have been placed in a position to do something to
bring about that resolution, a certain quantity of my literary
acquisitions have been organization-related materials. In the
fall of 1989, after the series of threats from organization
attorney Heller, I made a determined effort to acquire whatever
organization-related materials I could, sensing that they would
be needed in the attacks I also sensed were coming. In August,
1990, at the time of my renunciation, I split TGAC's stock into
four shares and gave them away with the rest of my assets as
described in paragraph 33 above. I had the hope and belief,
which I still retain, that TGAC would be a commercial success,
and that the four owners, all close friends of mine, would
benefit monetarily and have a lot of fun with the corporation.
I continued as TGAC's president, continued to produce, and TGAC
continued to care for its growing archive. From the
organization's actions and statements in the Yanny II
litigation, wherein it had taken my deposition on several days
in late 1991 and early 1992, and its actions and statements in
the Armstrong II litigation, where it had served a subpoena
duces tecum on the corporation, it became clear that the
organization was going to try to get its itching mitts on
TGAC's archive, invade its privacy and attack it as a way of
attacking me. On June 22, 1992, at a special meeting of TGAC's
directors, it was therefore decided, in order to remove any
reason for the organization to attack the corporation, to
transfer to me, Gerald Armstrong individual, everything in
TGAC's archive which related to the organization or my
litigation, and this transfer was effectuated the same day. I
still sensed that the organization was not going to be
dissuaded from its kamikaze course, and I still wanted to
protect TGAC's owners, whose only crimes were being my friends
and accepting my gift of stock certificates. I knew as well by
this time that the organization's leaders are paranoid,
schizophrenic, proudly describe themselves as "ruthless," and
would destroy any innocent person if it served their purpose in
attacking me. On June 23, therefore, I met with each of the
four who each decided at that time to give back to me his or
her shares. In that way these people would not become targets
in the organization's mad litigation war, and I would have the
freedom, as TGAC's major stockholder and president, to fight
the war on behalf of the corporation as I was called. Two of
the four, Michael Douglas and Nancy Rodes, had signed
settlement agreements similar to mine with the organization in
December, 1986, so were particularly vulnerable and worried in
the organization's attempt to make TGAC its litigation enemy.
In August, 1990 each of the four had received one share. In
early, 1991 by agreement between the shareholders, the four
shares were split into one hundred, and each shareholder had
given 5 shares to the corporation to sell to finance its
operations. Thus on June, 23, 1992, I received back eighty
percent ownership of TGAC (see also para. 21, supra, and Ex. L,
p. 556, 557). This proved to be a divinely timed move because
on June 24 I was served with the organization's amendment to
the Armstrong II complaint, naming TGAC as a defendant. Because
of my financial condition and the stress of the organization
litigation, which has rendered me over the past three years
completely incapable of dealing with certain clerical tasks,
which even ordinary people who are not fair game's targets can
easily perform, TGAC owes the IRS and the Franchise Tax Board a
couple of years' returns, but that is only a temporary
situation, which I expect to resolve in the next few weeks. Yet
even TGAC's failures to file seem to be divinely timed because
it surely disproves Mr. Wilson's Armstrong IV attack line that
"[T]GAC exists solely so that Armstrong may be "judgment proof"
(Ex. A. p. 5, l. 7). Only a madman would, when assaulted by
this organization's litigation machine and needing to be
judgment proof, let his judgment-proofing corporation approach
suspension. I am neither mad nor in need of any protection from
any judgment the organization imagines in its wild dreams it
might obtain. I own eighty percent of TGAC, and TGAC owns a
body of literature and art with considerable present value and
potential. It owns the rights to a number of my projects and
products, including whatever can be owned of the formula for
the Unified Field, which I was given not long after August,
1990. TGAC has a history and a lot of good will. TGAC did not
invite the organization's attacks, and even urges the
organization to dismiss all the litigation it has fomented
against TGAC. Nevertheless, TGAC will undoubtedly garner more
good will, good PR and societal acceptance as a result of the
organization's attacks, because society often judges one's
worth by one's enemies. Although no one should have to have
enemies, the organization's power structure, being so
villainous, is, in the minds of the vast decent human majority,
the best kind of enemy to have. TGAC's present value is in the
neighborhood of fifteen trillion dollars, so the organization's
claim of four point eight million is monetarily insignificant.
Nevertheless, and but for other reasons I will fight this

57. The organization filed the Armstrong IV complaint July 23,
1993 and the case was assigned to Marin Superior Court Judge
Gary W. Thomas. It served a lis pendens on me on August 8 and
then recorded it encumbering the Fawn property, which, as
evidence of God's Great Humor, the Waltons were that very
moment refinancing. On August 9 the organization mailed me a
request for production of documents, a copy of which is
appended hereto as Exhibit QQ, asking for a hell of a lot of
things, including everything I've written from the beginning of
time, and not unemphatically for the treatment for a screen
play entitled "One Hell of a Story," which I'd written and
registered in the spring of 1993, and for the authorship of
which the organization was claiming liquidated damages in the
Armstrong III lawsuit in Los Angeles. On September 16 the
organization mailed out another request for production of
documents by me, and similar requests to Mr. Walton and TGAC,
seeking inter alia, every financial record we possessed back a
year before the December, 1986 settlement. After some
extensions to figure out what under Heaven we were going to do
about the crazy-scary Armstrong IV lawsuit, on September 30 Mr.
Walton filed a demurrer and motion to strike the complaint, and
on October 4 I filed a motion to commence coordination
proceedings, followed on October 28 by an amended motion,
asking, because IV depends on the outcome of the LA cases and
shares with them common questions of fact and law, to have
Armstrong IV transferred from Marin to LA Superior Court and
coordinated with II and III. On October 21 Solina Walton filed
a motion to expunge the lis pendens, and on October 29 Judge
Thomas signed an order of expungement and awarded Mrs. Walton
$3500.00 in attorney's fees. On November 5 the organization
filed its opposition to the motion to commence coordination
proceedings, I filed a reply on November 9, and on November 10
in a pre-hearing minute order, a copy of which is appended
hereto as Exhibit RR, Judge Thomas denied the motion, ruling,
as again Humor would have it, that "[t]here are no common
questions of fact or law between this action and the Los
Angeles County actions." On November 12 the organization filed
an opposition to Mr. Walton's demurrer and motion to strike and
on November 17 he filed a reply supported by a declaration, a
copy of which, along with the exhibits thereto, is appended
hereto as Exhibit SS. In his declaration, Mr. Walton describes
our relationship over the years and the relevant events in our
Fawn period together. Exhibit D to his declaration is a letter
I write to him on August 14, 1990 in which I stated my
intention to give away my worldly possessions and forgive debts
owed me and laid out my immediate plans. Exhibit E is a letter
I wrote to him on August 23, 1990 while I waited in Marin
Traffic Court for my failure-to-obey case at which the charging
chippy didn't show. In the letter I list various physical items
then at Fawn and state my intention for their disposition. On
November 18 in a pre-hearing minute order, a copy of which is
appended hereto as Exhibit TT, Judge Thomas overruled the
demuurrer, and denied the motion to strike, stating that:

"this action does not seek or require a determination that
Armstrong breached the settlement agreement. Thus, this action
is not simply an attempt to avoid the (stay) orders in the Los
Angeles County actions." On November 30 the organization filed
motions to compel the production of the documents requested
from Mr. Walton, TGAC and me. A hearing on those motions is now
set for January 21, 1994. On November 30 I filed my verified
answer, a copy of which is appended hereto as Exhibit UU, the
verified answer of TGAC, a copy of which is appended hereto as
Exhibit VV, and a verified cross-complaint for abuse of
process, a copy of which is appended hereto as Exhibit WW.

58. The only remaining documents relevant to the Armstrong IV
lawsuit, other than letters to the other people in my life
whose debts to me I forgave in 1990, which I will not include
so as to not put them at risk, is my prayer and answer thereto
dated August 13, 1990, a copy of which is appended hereto as
Exhibit XX.

I declare under the penalty of perjury under the laws of the
State of California that the foregoing is true and correct.
Executed at San Anselmo, California, on January 13, 1994


Copyright © 1994, 2000 Gerry Armstrong

Copyright © Gerry Armstrong - All Rights Reserved.