Marin Superior Court filing part 1
[27 January 1998]


From: Gerry Armstrong <>
Newsgroups: alt.religion.scientology
Subject: Marin Superior Court filing part 1
Date: 27 January 1998


Gerald Armstrong
C/O George W. Abbott, Esquire
2245-B Meridien Boulevard
P.O. Box 98
Minden, Nevada 89423-0098
In Propria Persona



No. 157 680

a California not-for-profit religious corporation,




Date: 1/30/98
Time: 9:30 a.m.
Courtroom H


     Defendant Gerald Armstrong hereby requests an extension of
60 days to file his opposition to this Court's Order to Show
Cause Re Contempt, the hearing on which is presently set for
January 30, 1998, and requests that this Court withdraw its bench
warrant for his arrest, for the reasons set forth in the attached declaration.
     This request is based on the attached declaration of Gerald
Armstrong, and the files of record of this case, and such other
and further evidence as may properly come before this Court prior
to or at the hearing of this matter.
     Respectfully submitted.
DATED: January 26, 1998.
Gerald Armstrong


     I, Gerald Armstrong, declare:
     1. I have personal knowledge of the facts set forth in
this declaration and could competently testify thereto if called
as a witness. I am making this declaration in support of a
request for an extension of time to file my opposition to the
order to show cause re contempt obtained by plaintiff Scientology
organization on December 2, 1997 and received by me December 17,
1997. I also ask for a withdrawal of the bench warrant bearing
this case number apparently signed by this Court August 6, 1997,
so that I may participate in my defense, aspects of which I will
enumerate below, and because this warrant and the contempt order
upon which it is based were improperly and unlawfully obtained by
Scientology for an improper and unlawful purpose.
     2. I apologize for errors in form in this document and in
the procedure I'm following. I am not a lawyer, do not have
access at this moment to California statutes, cases and other
legal references, and do not have the time to become a lawyer or
learn better before my response to Scientology's application for
an order to show cause re contempt is due. I apologize
specifically for not being able to produce this document on
proper pleading paper. The substance of what I am seeking is
obvious, and it is obvious that it is within this Court's power
to schedule matters before it in the interests of justice, or for
any number of other reasons, e.g., a change of heart. It would be
an injustice, for the reasons set forth below, for this Court not
to continue the hearing on Scientology's OSC re contempt and not
to withdraw the bench warrant.
     3. In its moving papers, Scientology seeks to have me
jailed for 65 days and filed $13,000, plus seeks attorneys' fees
and costs, for 13 alleged violations of the Order of this Court
entered October 17, 1995. (Application, ("App") 10:12-15) These
alleged violations are that I "created and caused to be widely
disseminated by means of the Internet [between September 2, 1997
and October 20, 1997, six] documentary work[s] which discussed
CSI and the other beneficiaries," (Wilson declaration in support
of App, ("Wilson Dec"), 4:5-28); that on October 23, 1997 I
"caused to be widely disseminated by means of the Internet a
letter which [I] had apparently written previously to the Hon.
Alfonse D'Amato concerning the efforts of CSI to combat religious
discrimination in Germany," (Wilson Dec 5:1-3); that "in early
October [1997, I] voluntarily and willingly participated in a
videotape interview during which [I] discussed CSI and other
beneficiaries of the Order [ ]for broadcast on British
television," (Wilson Dec 5:12-15); that I flew to Berlin, Germany
sometime in October, where [I] gave a speech on or about October
26, 1997 [ ] making statements about L. Ron Hubbard and
complaining that the Church is misusing the U.S. Legal system and
blaming the Church, the U.S. Legal system and even [my] own
attorney for the fact that a contempt citation and arrest warrant
has been issued against [me], (App 5:19-24); that I "gave an
interview to the Berliner Zeitung, resulting in an article in
that publication," (Wilson Dec 5:24,25); that "on October 28 [I]
traveled to Hamburg, Germany where [I] appeared at an event
sponsored by self-styled "anti-cultists," [d]uring [which]
appearance [I] committed further violations of the Injunctions,
(sic) making numerous prohibited statements." (Wilson Dec 6:1-10);
that "[t]his appearance was reported on in the October 28th
edition of the Frankfurter Rundschau," (Wilson Dec 6:10,11);
"that on this same trip to Germany, [I] gave interviews to at least
three television interviewers which resulted in broadcasts on
Germany TV channels N-TV, B1 TV and SAT 1," (Wilson Dec 6:14-16);
that I "was interviewed by the regional newspaper, Taz, resulting
in the article of October 28, 1997," (Wilson Dec 6:16,17); and, that
"on November 26, 1997 [I] created another Internet posting
which purported to be a verbatim transcription of a complaint
which [I] had recently filed in the United States District Court
for the District of Nevada, [a] review of [which] virtually
unintelligible "complaint" reveals its true nature, a cynical
attempt to cloak [my] anti-Scientology ravings with the
litigation privilege," (Wilson Dec 6:20-26).
     4. In truth there are over 200 posts by me to the internet
allegedly in "violation" of the Order; thus I am facing about
three years in jail if Scientology is successful in its efforts
to punish me, plus a fine in six figures. I know that Scientology
is aware of all my 200 posts, because responses of Scientology's
agents indicate that the organization gets every post I make.
Since Scientology claims that each copy of any statement made by
me in "violation" of the "settlement agreement," as enforced by
this Court's Order, is a unique and separate "violation," since
this Court has supported that claim in its various orders
granting Scientology's various summary adjudication motions, and
since copies of my posts go to conceivably millions of people, I
am facing, therefore, essentially, and for all practical
purposes, life imprisonment.
     5. Scientology is claiming only 7 alleged post-judgment
contempts for my communicating to the media or other people about
the organization or its agents and their activities. Yet there
have been hundreds of such communications since Scientology first
attacked me after the 1995 judgment in this case. I am facing
potentially several years in jail and hundreds of thousands of
dollars in fines for these "violations" of this Court's Order.
Once Scientology establishes how many people have read copies of
my statements to the media, even if only by introducing into
evidence the media's official circulation statements, once again
I am facing, at a minimum, life in prison.
     6. Scientology has specifically not claimed as contempts
my various communications during much of 1997 to media and other
people in Canada about the organization, its agents and their
activities. On information and belief, this is because the
Scientology organization itself stands convicted in Canada of
criminal breach of public trust, is widely known in that country
as a criminal cult, and thus cannot as easily as it does in the
US, use the law to harass its targets. Scientology's attempting
to have anyone jailed for speaking in Canada about this criminal
cult and its attacks on that person would be summarily disposed
of, and I would imagine punished, as the legally impermissible
denial of basic human rights that the organization's actions are.
     7. Scientology also states that in addition to being
"criminally sanctioned by fine and imprisonment," my "actions
also warrant referral to the District Attorney for misdemeanor
prosecution under Penal Code Sec.166(4)." (App 2:14-16)
     8. Because of the quasi-criminal and criminal nature of
Scientology's charges and the punishment the organization seeks,
I have a right to defense by the Public Defender's office. I have
been in contact with Glen Becker of the Marin PD's Office,
advised him of my legal situation, and was advised by him almost
three weeks ago that I was being sent that day the necessary
financial statement form so that the PD may undertake my defense.
The PD will not undertake my defense until he receives my
financial statement, although Mr. Becker advised me that I
qualify and that the quasi-criminal and criminal matters with
which I am charged qualify for public defense. Because I have not
yet received the financial statement form from the PD, I must
myself make this request for an extension so that the PD has
enough time to prepare the proper papers and defense.
     9. As this Court knows, there is a massive file in this
case, (the record on appeal alone, without a word of live
testimony, is ten thousand pages) which will require considerable
time for the Public Defender to study and understand.
     10. This Court's Order, pursuant to which Scientology seeks
to have me jailed, is on its face illegal, and, being illegal, it
is judicially unenforceable. The illegality of the Order is an
issue which the PD must study and understand. A challenge of the
legality of virtually every word of this Court's Order is basic
to my defense.
     11. This Court's Order is also demonstrated as illegal by
post-judgment events involving Scientology and me, including, but
not limited to, Scientology's attempted judicial enforcement
efforts. These related actions must therefore be understood
toward the cross-examination of Scientology's lawyers and
managing agents, and the PD must have sufficient time to
assimilate the facts and law and to structure such examination.
     12. As this Court knows, although some of my defenses
presented in opposition to summary judgment were acknowledged
by this Court, although improperly rejected, I have valid defenses
to Scientology's charges which were not eliminated by summary
judgment. This Court did not acknowledge my defense of freedom
of religion in its grant of Scientology's summary adjudication
motions, and that defense, if acknowledged, is just as valid
today as it was two years ago. Because my liberty is at stake,
essentially for criticizing and legally attempting to reform a
"religion," this defense is squarely in front of this Court, and
cannot continue to go unacknowledged. When Scientology chose to
be a "religious" entity it gave up the right to have the secular
courts, for any reason except tort or crime, suppress its critics
or reformers. It is illegal and impossible to use any US Court to
prohibit a reformer of a "religion" from speaking out about that
"religion," even if the "religion" is an irreligious dangerous
cult like Scientology. It is as legally impermissible and
impossible to silence someone judicially about Scientology and
that person's experiences therein or therewith as it would be to
silence someone about Christianity and one's life as a Christian.
It is as legally impermissible as using the secular courts to
prevent Martin Luther from nailing his 95 Theses to the
Wittenberg door because he had an "agreement" with the Catholic
Church not to discuss his religious experiences in and with that
religion. This Court has not been given the authority to say that
God did not call Luther; nor has this Court been given the
authority to keep God out of religion in this religious freedom
case, over which, on the other hand, God did give this Court
authority. It is clear from this Court's rulings and non-
acknowledgment of the religious issues in this case that these
religious issues are difficult to confront and deal with. The
Public Defender must have sufficient time to become familiar with
the relevant Constitutional law and with the wealth of facts and
large pile of documents in and outside the record in this Court
which support a defense of religious freedom.
     13. This Court will recall that I disagreed with its
failure in its various rulings and comments to acknowledge the
duress, fraud and illegal purpose aspects and evidence in
Scientology's obtaining my signature on the legally unenforceable
and illegal "settlement agreement" on which the organization has
built and prosecuted this whole case. In the proceeding
Scientology seeks here; i.e. a hearing pursuant to criminal law
procedures, or a trial pursuant to Penal Code Sec.166(4), there
is a different evidentiary standard which will permit the
presenting of the facts surrounding the 1986 "settlement" that
this Court did not acknowledge in my previous summary
adjudication oppositions. The PD must have the time to understand
the facts of my complete 1969 to the present Scientology history,
the facts concerning Scientology's fair gaming of my attorney
Michael Flynn, the "settlement," and Scientology's post-
settlement attacks on me and other innocent people by which
Scientology dirtied its hands and thus relinquished its right to
judicially enforce the "settlement agreement."
     14. Even in his declaration, which is styled to obfuscate
and confuse, Wilson presents as fact and discusses my Scientology
posts and the depth of my knowledge about the organization.
     "Armstrong's claimed expertise concerning the Church,
     based on nothing more than having been the clerk
     entrusted with care of certain of Mr. Hubbard's
     personal files, gives him a superficial credibility,
     even though he has not been involved in any facet of
     the Scientology religion since 1981." (Wilson Dec 7:1-4)
This is false. It is also the standard Scientology black PR
attack line about my Scientology experiences. (See, e.g.,
complaint, Armstrong v. Miscavige,et al., USDC for the District
of Nevada, Case No. CV-N-97-00670-ECR (RAM) (Wilson Dec, Ex S,
p7). The truth is that my positions in the Sea Organization, the
top echelon of the global Scientology enterprise, included Ship's
Legal Officer, Ship's Public Relations Officer, Ship's
Intelligence Officer, L.Ron Hubbard's Deputy External
Communications Aide, Deputy Commanding Officer of Hubbard's
Household Unit, and L. Ron Hubbard Biography Researcher. Also
contrary to Wilson's assertion, since 1981 I have been intimately
involved with the litigation, fair game and black PR facets of
the Scientology enterprise, having been the target of these
antisocial practices without letup from that year to the present.
The PD must have time to understand my history, and why
Scientology continues to try to rewrite my history, why there can
be no peace for anyone until Scientology ceases completely, how,
in relation to these facts and truths, utterly enforceable and
wrong this Court's Order is, and how equally wrong are the new
charges I am facing.
     15. This Court will recall that, in its grant of summary
adjudication, it did not acknowledge the declaration by
Scientology attorney Lawrence Heller stating that the "silence"
condition of the 1986 "settlement agreement" applied to
Scientology as well as to me. This Court will recall that
Heller's declaration was used by the Scientology organization to
attempt to judicially prevent my deposition from going forward in
a case against Scientology in which I had been subpoenaed to
testify. This Court will recall that when, on a motion for
reconsideration, this Court's attention was directed to its
failure to acknowledge the Heller declaration, this Court ruled
that it did not have to acknowledge that potentially vital
evidence because it was not new. Now the Heller declaration again
becomes relevant, and cannot be avoided by this Court; since it
is Scientology's actions in attacking me *after the Judgment was
entered in this case* which precipitated my actions in response,
and for which Scientology now seeks to have me jailed and fined.
See, e.g., Wilson Dec Ex.K, my October 18, 1997 letter to the
Congressional Commission on Security and Cooperation in Europe,
p7 of 9 re falsehoods in Scientology's IRS Form 1023 discovered
by me in January 1997; Wilson Dec, Ex. S, complaint in Armstrong
v. Miscavige, supra. Because the Heller declaration can now be
introduced (again), and cannot be kept out as evidence, it is
potentially dispositive of not only Scientology's alleged
contempts, but the whole case against me. Scientology's hands are
unclean in the matter in which the organization now seeks this
Court's assistance. The Public Defender must have time to get to
the bottom of these facts, this Court's series of rulings in this
matter, and the law of the case, particularly unclean hands and
     16. The Armstrong v. Miscavige litigation opens up a
completely new defense, while demonstrating again the Order's
impossibility, unenforceability, risibility, and, ultimately,
illegality. It is clear that this Court cannot control what
happens in or flows from the US District Court in Nevada. Again,
it was Scientology's post-judgment acts attacking me which are
the basis for the federal action. It is not, as Mr. Wilson states
in his declaration, "a cynical attempt to cloak Armstrong's anti-
Scientology ravings with the litigation privilege." I am
represented in Armstrong v. Miscavige by attorney George W.
Abbott of Minden, Nevada, and they are his words that Wilson
black PRs. The PD must have time to understand Scientology's
attacks leading up to the filing of Armstrong v. Miscavige, and
the impact of that case and Federal-State relationships on the
illegal Orders of this Court.
     17. The truth is that none of my statements over the years
about Scientology, its leaders and their abuses and civil rights
violations are "ravings." The truth also is that the Armstrong v.
Miscavige litigation is not an attempt to cloak my responses to
Scientology's fair game attacks with the litigation privilege,
but an effort, using the judicial system, as it was wisely
intended, to have Scientology (efforts through human
communication having been spurned) cease its attacks. The truth
is that these Wilson falsehoods are part of Scientology's black
PR campaign against me. It is clear that this Court knows what
"fair game" and black PR" are. It is clear that I cannot legally
be prohibited judicially from bringing about the cessation of
Scientology's attacks, either judicially, or, extrajudicially by
the various free speech actions I am accused of in Scientology's
OSC application and supporting Wilson declaration. Nor can I
legally be prevented judicially from defending myself from attack
until such cessation is achieved. To jail me for a lifetime, or
several years, or even a day, would illegally prevent me from
defending myself from Scientology's wrong, which, in human terms,
and as any reasonable person would see, caused the defensive
actions for which I would be jailed. The PD must have time to
study Scientology's and its agents' black PR campaign against me,
and understand the Constitutional issues and other legal issues
     18. It is clear that I have a right, which cannot be taken
away by this Court's illegal order, to collect evidence in
Armstrong v. Miscavige from anyone to whom I care to communicate
and will communicate with me. It is clear too that this Court
cannot legally strip or limit my various privileges in another
court, and it is clear that this Court cannot limit my ability,
and indeed duty, to conduct discovery and do investigations in
the matter before that other court. It is clear that this Court
cannot limit what I can say to anyone in the process of legally
gathering evidence in the Armstrong v. Miscavige litigation. This
Court's ruling, in its grants of summary adjudication, which
limited what I could say to people when gathering evidence for
trial, at that time in my Bankruptcy case, Scientology v.
Armstrong, US Bankruptcy Court for the Northern District of
California, Case No. 95-10911 aj, Adv. No. 95-1164, was and is
unreasonable, impossible and itself illegal since it is
demonstrable obstruction of justice. This Court cannot legally
prohibit me from even going so far as to set up a legal anti-
Scientology organization or network to gather evidence against
the organization in the Armstrong v. Miscavige matter, in my
other claims against Scientology, or indeed in the matter before
this court. The PD must have the time to study and understand the
impermissibility of this Court's prohibitions as they relate to
my right to discovery and my litigant's privileges; as well as
the inherent violations of the Fourteenth Amendment to the US
Constitution, in this case, in Armstrong v. Miscavige, and
throughout Scientology's sixteen year war attack me.
     19. I have other claims against Scientology as well, for
its black PR of me in its IRS form 1023 response, on which its
tax exemption is based, and for its many threats and other
attacks over the past 10 years and beyond, pursuant to RICO and
civil rights statutes. For this reason too this Court's order is
illegal and unenforceable. I have communicated within the past
year to David Miscavige to attempt to resolve these matters by
dialogue. Miscavige has responded with attacks, threats, further
black PR and further fair game, including fair game within this
Court's own rooms. The PD must have time to study and understand
these facts, issues and bodies of law.
     20. Neither the black PR spread to Watchman Fellowship,
although dated May, 1993, nor the black PR in Scientology's 1023
submission, although filed with the IRS in 1991 or 1992, was
produced by Scientology in discovery in this case prior to this
Court's grant of summary judgment. Both documents were of a type
or nature of documents which Scientology was ordered to produce.
This fact, by itself, is enough to render unenforceable this
Court's Order, and to require the voiding of the grant of summary
judgment. Coupled with the Order's other deadly infirmities and
Scientology's illegal enforcement actions, the organization's
withholding of these documents takes on considerable legal
consequence. The PD will have to get to the bottom of
Scientology's abuse of discovery and the extent of its other
withheld black PR activities.
     21. This Court will recall that throughout this litigation
I have claimed that David Miscavige is the managing agent of the
Scientology enterprise. A November 14, 1997 decision in the case
of Wollersheim v. Scientology, LA Superior Court Case No.
C332027, established that fact emphatically and once and for all.
Miscavige is the person responsible for Scientology's litigation
attacks on me, its public statements about me, its black PR of
me, its fair game on me. It will be necessary at the trial in
this matter for the PD to examine Miscavige, my de facto accuser,
as well as other Scientology agents. Miscavige is known to avoid
service of process and to hide out to avoid service. Sufficient
time is required for the PD to learn about Miscavige and the
other Scientology leaders, to bring the necessary motions to
compel Miscavige's and other Scientologists' presence at trial,
and to understand the Scientology enterprise's structure,
philosophy and practices.
     22. I have spoken to several lawyers and many other
reasonable people in all walks of life about this Court's Order,
the facts underlying it, and Scientology's enforcement actions.
Virtually all of these people who have listened to the whole
story have said that they believe that this Court's Order is
unfair, unjust and judicially unenforceable. Attorney Abbott,
writing on February 12, 1997 to Andrew Wilson, and requesting
that Scientology correct the black PR on me the organization sent
to the Watchman Fellowship, stated:
     "I have advised Mr. Armstrong that he is free to
     communicate orally, in writing or by any other legal
     medium available to him to fully correct the lies and
     distortions in your letter and dead agent document. I
     have advised him that he is free to communicate to
     anyone he believes may have been or may be exposed to
     this black PR, and that he is free to explain why
     Scientology and its leaders have created and
     distributed these documents.
          I have further advised Mr. Armstrong that
     Scientology cannot legally prevent him from correcting
     this libel with threatened enforcement of your
     organization's "settlement agreement" of December,
     1986. Each moment you and your seniors prevent him
     from telling the truth to whomever he chooses in
     rejection of your documents' attack on his character
     you are increasing his damages."
All of the "contempts" Scientology claims in its application
occurred after Abbott's February 12 letter containing this
advice. The PD will need sufficient time to understand these
facts and the relevance and impact of such clear legal advice, in
addition to public agreement, in the midst of colossal
Constitutional questions, and when charged with violations of an
illegal order. The PD will also require time, particularly
because of this Court's misinterpretation of relevant law and
Constitutional issues, to examine the need at trial for an expert
in the areas of law involved in this case to interpret those
areas and to relate the complex and momentous facts in this case.
     23. All of the internet "posts" Scientology claims are
contempts were made by me to the newsgroup alt.religion.
scientology ("ARS"), a cyberspace message center and "meeting
place" for people who seek an end to Scientology's fair game
doctrine, and who derive a certain amount of safety from fair
game by "meeting," communicating and reading others'
communications on the newsgroup. ARS is free to everyone, and no
one is barred from participating, including Scientologists and
Scientology agents, who participate, for the most part, by
practicing fair game against the people dedicated to ARS's goal
of ending that dangerous doctrine, and ending the threat fair
game is to so many people around the world. Participation in ARS
is by posting to the newsgroup composed messages relating to
Scientology. Much of the information provided by participants
makes its way onto "permanent" web sites or is otherwise
"permanently" archived. A number of ARS participants are
defendants, some like myself in propria persona, in Scientology
litigations. Some people post anonymously; some post openly,
using their real names, as I do. ARS is sometimes called a
Wittenberg Door, although it is a door which is not owned by the
"church." Scientology has attempted to destroy the door with
illegal internet attacks and fair game, to overwhelm the door
with "spam" barrages, and to terrify and silence the people who
use the door with raids on their homes, seizure of their
"religious" texts, their computers and their records, black PR of
the most vicious kind, lawsuits and threats of lawsuits, lies and
more lies.
     24. Many documents filed in Scientology litigations around
the world are posted to ARS, often the day they are filed in
court. I posted, e.g., my Appellant's Opening Brief filed in
August this year, and I have made several posts commenting on
proceedings and facts in this case. I have posted the complaint
in Armstrong v. Miscavige. (Wilson Dec Ex S) Within the past
week, a Scientology agent, who goes by the anonymous name
"WGERT," posted the bench warrant this Court apparently signed
August 6, 1997. The instant document I will also post right away
so that Scientology has as much notice of my filing as possible.
I have found that all the work of preparing documents and making
them public is one of the prices for finding relative safety
through faith in free speech, openness in our courts, and getting
the word out. What flows on ARS's field of free speech is the
participants' knowledge of and experiences with Scientology's
nature and activities, and the participants' on-going experience
of participation. Since I have had a very long and intense
experience with Scientology and continue to have an almost all-
consuming, virtually full-time and ceaselessly threatening legal,
extralegal and psychological relationship with the organization,
and its leader David Miscavige, I have potentially a great deal
to give and receive through participation in ARS. Posts to ARS
have averaged some 300 per day for the past few years. ARS has
no organization, but is sometimes used for organizing the
unorganized participants. Two of its main organizing activities
are the present, continuing and global picketing of the
Scientology organization and protesting its human rights abuses,
and the announcement of Scientology-related legal proceedings. I
participate in these pickets and attend these legal proceedings
as circumstances permit.
     25. The PD will need the time to understand the
relationship of the internet to Scientology's suppression of
civil rights. This Court's Order impermissibly acts to strip me
of the Constitutional guarantee of freedom of association, indeed
freedom of assembly. The PD will need sufficient time to relate
this "new" electronic medium and forum to the facts in this case
and the civil rights issues. He will need to plug into the truly
global internet archives on Scientology, its abuses, litigations,
critics, reformers, leaders, policies and practices. It is
entirely possible that one of the internet freedom organizations
will wish to become involved in this case because of the amazing,
newsworthy and precedential situation of an internet critic of a
"religion" being threatened with jail for his religiously
motivated free speech posts to a free speech newsgroup dedicated
to free speech about that "religion." The PD will need time to
approach such organizations or interested resources.
     26. This Court's Order essentially subjects me to a modern-
day slave condition, since this Court has also ruled that
Scientology can attack me in any way it wants and I may not
respond. This Court has impermissibly and illegally stripped me
of the right and power to defend myself that non-Scientology
slaves possess. This is what US Courts "lawfully" did to skin-
color-based slaves, owned by "legal" contract, prior to the
Emancipation Proclamation, but may do no longer. The PD must have
sufficient time to understand how Scientology's "settlement
agreement" and this Court's enforcement thereof are violative of
the Thirteenth Amendment to the US Constitution which outlawed
slavery. The PD must have sufficient time to prepare a vigorous,
uncompromising and far-reaching opposition to these enslavement
actions. It is also possible that other human rights groups which
oppose slavery in all its nefarious forms, e.g., the ACLU,
Amnesty International or the NAACP, would wish to participate in
the opposition to Scientology's slavers and this Court's abetment
thereof. Thus the PD must have the opportunity to explore such
participation, possible assistance, intervention, or amicus
curiae actions.
     27. This Court will recall that I have opposed this Court's
enforcement of Scientology's "settlement agreement" because it
was, inter alia, psychologically impossible for me to remain
completely silent about the organization, my experiences
therewith, and this Court's rulings and their illegality,
certainly while Scientology continued to attack me day in and day
out around the world. Scientology has made my mental state
central to its black PR campaign against me, and even in its
filings before this Court. (See, e.g., Scientology's descriptions
of me in its application for an OSC: "a calculating, deliberate
outlaw," (App, 4:6); "a superficial credibility," (App, 6:7);
"feels that he is immune from the actions of this Court and that
he can disregard its orders with impunity," (App 10:6,7).)
Scientology supports its application for its OSC with Wilson's
statements of fact about my motives. (E.g., that I "testified of
my intention to ignore the settlement agreement and Judge
Sohigian's order," (Wilson Dec 2:12); that my "intent to harm and
to flout this Court's lawful orders are evidenced by the
introduction of the Internet posting in which [I] announce the
[Armstrong v. Miscavige] lawsuit with a "Happy Thanksgiving"
salutation to CSI and the other beneficiaries," (App 3:21-4:1);
that I "apparently feel[] that [I am] immune from the actions of
this Court and that [I] can disregard its orders with impunity,"
(App 10:6,7). Scientology stated regarding the state of my mind
in its 1023 submission:
     "As we shall demonstrate below, all this decision [of
     Los Angeles Superior Court Judge Paul G. Breckenridge,
     Jr., filed June 22, 1984] ever involved was Armstrong's
     state of mind, which subsequently obtained evidence
     proved conclusively to be one sordid, sado-masochistic
     nightmare. Furthermore, Armstrong's state of mind
     horror stories have fallen on deaf ears in recent
     litigation. Relying on Armstrong or the Armstrong
     decision is wholly unjustified."
As this Court knows, I must be fully capable of complying with
this Court's Order for this Court to be legally able to enforce
that Order. The PD must have sufficient time to come to
understand my mind, Scientology's actions in conveying its own
warped version of my mind to the world and particularly to this
Court, and to be able to structure and detail his examination of
Scientology's witnesses on these subjects. It is imperative that
a psychological expert who understands the brainwashing and
attack mentality aspects of Scientology, as well as the effects
of these aspects on a Scientology target at this point in
history, must be located and retained for this defense. As this
Court is aware, Scientology considers itself the best and only
workable mental therapy program in the world and that Scientology
avers that its own most untrained practitioners know more about
the mind than any psychiatrist. Just today another Scientology
agent stated in a copyrighted spam post to ARS that Scientology
possesses "the largest, broadest body of information on the
subject of human behavior, the mind and life that has ever been
available." Scientology sells its "mental technology" to its
customers with promises that this "technology" produces people
fully capable of, e.g., reading minds or "exteriorizing" and
reading other people's private files. The PD must have sufficient
time to come to grips with this, and to seek the professional
help he will need.
     28. Scientology's IRS Form 1023 response, which was filed
in 1991 or 1992, contains statements reflecting the IRS's
depending on my testimony and on the 1984 decision against
Scientology in the IRS's refusal to grant tax exempt status to
the organization until that time.
     "the Service has continuously thrust the Armstrong case
     at us, demanding an explanation."
          "The IRS CID, however, absorbed Breckenridge's
     findings as the definitive statement of what
     Scientology is, and used this decision and the Flynn
     witnesses who testified at the trial as the nucleus of
     their investigation."
Within the past year there have been stories in major newspapers
about the suspicious circumstances surrounding Scientology's
obtaining its IRS tax exemption in 1993, about Scientology's
threatening and pressuring IRS personnel, and about Scientology's
secret agreement with the IRS. Within the past month, this secret
agreement was leaked, and published by major newspapers.
Scientology's fraudulently obtaining its tax exemption is at this
moment a very live controversy. Scientology director Miscavige
has made a public statement that involved in the organization's
secret deal with the IRS there was a tax bill of one billion
dollars, a sum which dwarfs whatever Scientology claims it paid
me. The PD must have sufficient time to get to the bottom of
Scientology's fraudulently obtaining its tax exemption, my
participation in the on-going effort to correct that fraud upon
the United States and the world, and how that participation
cannot legally be judicially prohibited.
     29. As this Court knows, I have been stating publicly as
called upon since 1989 that Scientology, its agents, lawyers and
leader have been lying and are lying about me, my experiences in
Scientology, my Scientology litigation, and my non-Scientology-
related thoughts, words and deeds. Scientology's lying is the
basis of its obtaining from this Court this OSC, the basis of its
earlier contempt order, the basis of this Court's Injunction
Order, and the basis of all Scientology's litigation and
extralitigation attacks on me from the day I left the
organization. Scientologists are expected to lie for the
organization, may be punished for not lying, and, indeed, lying
for the organization is what makes someone a Scientologist. Lying
is essential for the operation of Scientology's fair game
doctrine. Scientology's witnesses are expected to lie for the
organization and are trained to lie. Exhibit G to Wilson's
declaration, and providing further understanding of the
phenomenon of Scientological lying, is a copy of a post to ARS
dated October 14, 1997 entitled "Lie, Lie, Lie, Lie, Lie, Lie,
Lie, Lie, Lie, Lie, Lie, Lie, Lie, Lie, Lie." The PD must have
sufficient time to study Scientology's history of lying,
particularly lying under oath in legal proceedings, and to gain
an understanding of the brainwashing of Scientology's witnesses,
the organization's witness drills and techniques, the
organization's system of punishment, and the complete and robotic
bias of its witnesses.
     30. Scientology says that it seeks both a contempt
proceeding against me pursuant to CCP Sec.1218 and misdemeanor
prosecution under Penal Code Sec.166(4). (App, 2:13-16) Since
this has the color of double jeopardy, it may be advisable, and
certainly, given the unlikelihood of my quitting this crusade
anytime soon, judicially economic, to hold one proceeding. It is
altogether possible that I could elect the more serious of the
proceedings, the Penal Code prosecution by the DA. A jury trial
is, as is arguably obvious by everything Scientology does to
avoid one, the quickest, most certain and, next to this Court's
dismissal of all of Scientology's claims, most sensible,
resolution of this entire case. The PD will need time to explore
the double jeopardy issue, to decide which procedure is right for
this matter's facts, to communicate with the DA about its
dismissal, and so forth.
     31. As this Court knows, in many countries of the world,
Scientology is a controversial topic, and is widely viewed as, in
effect, a criminal cult. I am accused in Scientology's
application for its OSC of giving media interviews in Germany and
being filmed for UK television. Wilson states, e.g., in his
     "I am informed and believe that on October 28 Armstrong
     traveled to Hamburg, Germany where he appeared at an
     event sponsored by self-styled "anti-cultists" Renate
     Rennenbach and Ursula Caberta. (Rennenbach and Caberta
     have been engaged for the past several years in
     attempts to discredit the Church through various means
     and have lobbied various German government entities to
     essentially legalize discrimination against members of
     the Church of Scientology because of their Church
     membership. In fact, Germany has been censored for the
     past three years by the United Nations and the Helsinki
     Commission for just such discrimination. The United
     States Department of State has also found a pattern of
     human rights abuses by Germany against Church members.)
     (Parens are Wilson's) (Wilson Dec 6:1-9)
This is false. On information and belief, Ms. Rennenbach's and
Ms. Caberta's oppositions to Scientology are due to the
organization's human rights abuses. Scientology's black PR
attacks on these women are disgraceful. In Germany, Scientology
is not recognized as a "religion," but is recognized as a
commercial enterprise with a totalitarian and abusive nature and
global political goals. On information and belief, the United
Nations did not censor Germany at all in the past three years,
and certainly not in relation to Scientology. Everyone in Germany
may communicate as freely about Scientology as about, e.g., ripe
cheese. It is Scientology, through attack, threat, illegal
"contracts," and illegal enforcement thereof, which attempts to
censor its own members, and censor anyone who would criticize or
attempt to reform its antisocial practices. On information and
belief, the US State Department's support of Scientology's attack
on Germany, and on other countries which have acted to restrain
the organization's abusive practices, is misguided, and stems
from Scientology's fair game attacks and false statements,
including its false statements about me. Germany and other
countries oppose Scientology because of what the organization is
doing to people like me: its use of a US Court to strip me of my
basic rights to freedom of conscience, freedom of speech, freedom
of religion, freedom of association, freedom from slavery, and
due process. There are people in a number of countries who are
aware of Scientology's legal attacks on me, and who are observing
the US Courts' actions and rulings in these proceedings. On
information and belief, there are thousands of Scientologists and
ex-Scientologists in the US who have been shuddered into silence
by Scientology and whose basic freedoms will start to be regained
once Scientology's efforts to judicially silence me are stopped.
The PD must have sufficient time to understand the scope and
intensity of the international controversy about Scientology, its
attacks on people and its other abuses, and its use of the courts
to harass its targets including me. The PD must have time to
understand the impossibility and illegality of judicially
prohibiting my participation in that international controversy.
The PD must have time to understand the national undesirability

[End Part 1 of 2]


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