Response to Sleazy Scientology Op in Beautiful B.C.

[gerry armstrong]

(posted and emailed)

See 4/18/98 declaration of Scientology agent Sheila Werner and 4/17/98
declaration of Scientology attorney Andrew Wilson posted separately.
This was written for filing in the case of in the case of Armstrong v.
Miscavige, et al., United States District Court, District of
Nevada, No. CV-N-97-00670-ECR(RAM)("Armstrong VI")

DECLARATION OF GERALD ARMSTRONG

I, Gerald Armstrong, declare:
1. I am the plaintiff in this case. 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 oppositions to a motion by defendant
Scientology corporation Church of Scientology International ("CSI") to
dismiss the complaint, and a motion by defendant Religious Technology
Center ("RTC") to dismiss the complaint.
2. I was inside Scientology for many years, held several
key positions such as public relations officer, legal officer,
intelligence officer and archivist/researcher, and gained considerable
knowledge of organization structure, personnel, policies and
practices. I worked closely with Scientology founder L. Ron Hubbard
and gained considerable knowledge of his history, activities, writings
and intentions. I left Scientology when I discovered and documented
organization-wide fraud concerning Hubbard's history, accomplishments,
intentions, the promises of Scientology's mental healing "technology"
and the organization's nature and activities.
3. Because of what I knew of Scientology and Hubbard
fraud and other abuses, immediately after leaving the organization,
and continuing to this day, I was designated by Scientology leaders as
an "enemy" and became a target of Scientology's policy and practice of
attacking "enemies," called, and judicially condemned as, "fair game."
Hubbard stated in one description
"ENEMY - SP ("Suppressive Person") Order. Fair Game. May be deprived
of property or injured by any means by any Scientologist without any
discipline of the Scientologist. May be tricked, sued, or lied to or
destroyed." I view fair game as a philosophy and practice of
opportunistic hatred; Scientology leaders seize any opportunity to
cause designated "enemies" harm.
4. Actions since 1982 by Scientology's personnel or
agents against me pursuant to fair game, include:
- filing five lawsuits against me;
- following, surveilling and harassing me and my wife;
- spying in our windows and upsetting our neighbors;
- attempting to involve us in a freeway "accident;"
- assaulting me;
- striking me bodily with a car;
- threatening to put a bullet between my eyes;
- attempting on more than 12 occasions to have me prosecuted
on false criminal charges, including by the FBI;
- stealing a manuscript and artwork from my car;
- filing false sworn statements about me in various
litigations;
- extracting and disseminating information from my supposedly
confidential auditing (psychotherapy) files;
- illegally videotaping me;
- attempting to entrap me in the commission of a crime;
- threatening me on several occasions if I testified about my
knowledge of Scientology;
- threatening my friends;
- subjecting my attorneys to years of fair game;
- subjecting me to a massive international "black propaganda"
campaign.
5. Black propaganda or "black PR" is the term Hubbard
gave to Scientology's policy and practice of destroying a target's
reputation and credibility or public belief in him by the manufacture
and spreading of falsehoods about him. Over the years Scientology has
published and disseminated a small mountain of black PR on me, falsely
accusing me of perversities and crimes, including crimes against
humanity, in an ongoing effort to assassinate my character.
Scientology black PR on me disseminated by organization agents in 1996
to principals of Watchman Fellowship, a Christian research and
apologetics organization, is the basis of this lawsuit.
6. Appended hereto as Exhibit A is a true and correct
copy of the 1984 decision of Los Angeles Superior Court Judge Paul G.
Breckenridge, Jr. in the first case in which Scientology sued me, LASC
No. C 420153. Judge Breckenridge condemned Scientology's fair game
policy:
"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 Church 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. A, 8:18-9:4)
The California Court of Appeal affirmed the decision and judgment,
Scientology v. Armstrong (1991) 232 Cal.App.3d 1060, 283 Cal.Rptr.
917.
7. I have testified more than sixty days in trial or
deposition is some twenty Scientology-related cases, and written and
executed approximately one hundred declarations which have been filed
in perhaps fifty cases. I am an expert in Scientology's policies and
practices, particularly its fraud and fair game doctrine, and I have
testified in legal proceedings as an expert qualified in these areas.
8. CSI and RTC are components of the global Scientology
syndicate. All of the components are under the direction and control
of David Miscavige, also a defendant herein.
9. CSI and RTC assert that I am not a resident of Nevada.
This is not true. I have considered myself, and have legally been, a
resident of Nevada since November, 1997. I have never since that time
considered myself a resident of any other state or province than
Nevada, and have never stated to anyone since that time that I was not
a resident of Nevada. I have had a post office box in Nevada since
November 21, 1997, where I have received mail, including substantive
non-junk mail. Appended hereto as Exhibit B is a true and correct copy
of the receipt for a year's rental of post office box no. 2802,
Minden, NV 89423. I will, of course, now change my box location and
number. I have a Nevada driver's license, and do not have a driver's
license from any other state or province. I have work in Nevada, am
actively engaged in that work, and keep my personal property in
Nevada.
10. CSI and RTC support their false assertion that I am
not a resident of Nevada with a declaration by Sheila M. Werner, who
states that during a conversation with her on April 5, 1998 I "told
[her] that I had recently been in Nevada but that [I] did not plan to
live there and was there only for legal matters." (Werner Decl. p 2,
para 9) This is completely false.
11. As Ms. Werner states, she called the telephone number
of my mother's home in Chilliwack, B.C., Canada a number of times, and
spoke to either my mother or me, and on a couple of occasions I called
her back at her Vancouver, B.C. number. We met as she says on two
occasions, in the Chilliwack Starbucks and another cafe in Chilliwack,
called After Thoughts.
12. During our initial telephone conversations Ms. Werner
said that she is involved in many facets of the Canadian movie/TV
industry as an actor and in other production capacities and she wanted
to make contact with me and give me a script writing program. She said
that there are all kinds of opportunities in the industry and that she
had gotten the idea that I might be writing a script. She said that
she is writing scripts and described how wonderful the program makes
script writing. She said that she wanted to give me the program so
that I could run it on my computer. I asked her if she had been in
touch with anyone connected to the Scientology organization and she
said that she had not in several years. She said that her ex-husband
is involved with Scientology but that she didn't know in what way. She
said that she knew about my being a Scientology target and my
supporting the effort to reform its irreligious practices. She said
that she had read of my involvement in these things on the Internet,
mentioning specifically the newsgroup alt.religion. scientology
("ars"). She said that the script she was writing wasn't about
Scientology, and that she wouldn't do anything directly about its
irreligious practices because of the threat of Scientology retribution
directed at her children.
13. Since December, 1981 I have been alert to
Scientology's actions of operating agents to get close to me or having
thugs threaten or attack me. My sociableness, social contacts and
interactions with almost all people are significantly impacted by that
continual alertness. When she first contacted me I was immediately
alert to the possibility that Ms. Werner was a Scientology agent, and
I continued to be alert to that possibility throughout the Werner
operation. I was alert to the fact that Ms. Werner's way of
communicating, including but not limited to the repetition of phrases,
her freneticness, and the questions she asked, made me think she had
been scripted and rehearsed in what to say to me. At the same time, I
gave Ms. Werner the benefit of the doubt and did not cut off
communication with her nor communicate with her in any way but with
respect. On both occasions when we met I bought her a coffee.
14. When in our first conversations Ms. Werner offered to
give me the scriptwriter program to run on my computer I was alert to
the possibility that Scientology's leaders would attempt to damage my
computer or have me prosecuted or even raided for a "copyright
violation" or other concocted charge. I therefore declined Ms.
Werner's offer to give me the program and told her that perhaps some
time when I was in the Vancouver area I could drop by her home and see
the program on her computer.
15. During the conversation in Starbucks Ms. Werner asked
me where I had been and what I had been doing in Nevada. I told her
that since November, 1997 Nevada had been my residence, that I was
intending to live here and that I had most of my personal belongings
here. I said that it was my legal situation in combating Scientology's
fair game attacks which drew me to Nevada, and that I had been doing,
was doing and would be doing legal work in a law firm in Nevada. I was
extremely careful to say in every sensible way that Nevada is my
residence, because I did not want to give Scientology, if Ms. Werner
was, as I suspected, its agent, any way of "misinterpreting" for its
"legal" purposes what I was saying about my residency. Ms. Werner's
assertion that I said that I did not plan to live in Nevada is
therefore a blatant and inexcusable lie.
16. Ms. Werner states:
"On 29th of March 1998, I called for Gerry Armstrong
at this mother's house. The lady whom I believe to be his mother
informed me that Gerry had gone to check out a sports club at Vedder
Crossing to see if he wants to join." (Werner Decl. 2, para 7) This is
untrue. I went to Vedder Crossing to run with a group of runners who
run there every weekend. Anyone not a "member" is welcome to run with
them. I had no intention of, or interest in, "joining " that club
because I had no intention of staying in that area. I have also run
with runners here in Reno who are members of the Silver State
Striders, and I expect I will continue to run with them. I would have
already joined the Striders, but I am very cautious about social
contacts because of the continual efforts by Scientology's leaders and
agents to cause trouble to me and those close to me.
17. During our meeting at Starbucks Ms. Werner gave me two
publications, The Georgia Straight, Vancouver's major weekly
newspaper, of April 2-9, 1998, and Reel West Digest "the Directory for
Film, Video and Multimedia Production in Western Canada," 1997
edition. True and correct copies of identifying pages from these
publications are appended hereto as Exhibit C.
18. During our meeting at After Thoughts Cafe I asked Ms.
Werner directly if she had spoken to anyone connected to the
Scientology organization about me. She said no. I asked her if she had
spoken to anyone connected to the Scientology organization about
speaking to me. She said no. I asked her if she had been asked by
anyone connected to the Scientology organization to contact me or ask
me anything. She said no.
19. Also during the After Thoughts meeting, Ms. Werner
wanted me to take from her a copy of a script she said she had written
involving the "X-Files" TV program theme and characters. She said that
the script she had written concerned a sort of viral mutation like
"mad cow disease." She handed me her "script" but I did not pick it
up. She also had a typed receipt and confidentiality agreement for her
"script" which she handed me and wanted me to sign. I did not sign the
document and did not pick it up. I told her that I suspected that she
was an agent for Scientology, that the organization perhaps wanted to
get my fingerprints on her "script" for some malevolent purpose, and
that perhaps the organization wanted to set me up in some kind of
"copyright violation" scenario. It is a well known fact that
Scientology, with its also well known litigation machine, uses
"copyright law" to raid, attack and ruin targeted "enemies." When I
stated my suspicion, Ms. Werner became "indignant" and quickly left
the cafe.
20. Now Ms. Werner has shown that indeed she was being
operated as a Scientology agent, on orders, coached and drilled to get
close to me in order to compromise, entrap or frame me in some way.
Her telephone calls to me and my mother and meetings with me were at a
minimum to create a "context" to give believability to the lie the
Scientology leaders needed from her in order to "support" their
"legal" tactic by which they could possibly avoid responsibility in
the real claims and issues in this case. Ms. Werner lied about her
reasons for contacting me, lied about her interest in giving me a
computer program, lied about finding out about me on the Internet,
lied when she said she had not been directed by anyone connected to
Scientology to contact me, lied when she said she had not spoken to
anyone about me, and lied about what I had stated very clearly
concerning my Nevada residence. To Scientology agents it is perfectly
acceptable, even laudable, to lie or testify falsely about me because
I am "fair game."
21. I had actually been planning to live in Nevada for
several months before I made this State my residence in November,
1997. Over those several months I made arrangements so that I could
have some protections in place in Nevada against expected Scientology
attacks, and a job situation in place in Nevada when I established my
residence here. By November, 1997 those things were reasonably in
place and I began to work in Nevada. I made some trips back to Canada
thereafter, principally to help my family, help ready my mother's home
so it can be sold, and help my brother with some renovations projects
at his home. Of course I continued, as I am continuing in Nevada, my
actions in bringing to light Scientology's fraud, abuses and dangers,
correcting the injustices Scientology is perpetrating against me and
others in the legal arena, and countering the black PR campaign the
organization continues against me. I was able to take this time away
from Nevada at the start of my residency here in no small part because
the various Scientology defendants in this case avoided for a great
length of time accepting service of the summons and complaint. I did
not, however, during all that time, ever say or consider that I was a
resident of anywhere other than Nevada. Even if I were gainfully
employed in Canada, which I am not, and even if I wanted to live
there, I cannot live at my mother's or brother's homes because of the
continual threat to them of attack or harassment from the Scientology
organization and its agents. No matter where I reside or even stop to
rest, I avoid letting Scientology's agents find out where I am as long
as sensible or possible; thus will not now divulge any location where
I stay or intend to stay in Nevada, or elsewhere. I will be available
in Nevada for all proceedings in this case which require my physical
presence.
22. CSI and RTC also supports their motions to dismiss
with a declaration executed by attorney Andrew Wilson which contains a
substantial number of untruths. Mr. Wilson states:
"In late January, 1997, I learned of actions by Mr.
Armstrong that I believed were clear violations of the [October, 1995]
Injunction. Armstrong sent to the Hon. Ronald M. Whyte, the United
States District Judge presiding over three cases in which the
plaintiff is Religious Technology Center ("RTC"), a beneficiary of the
Injunction, a letter and lengthy declaration disseminating information
denouncing CSI and its related entities. ś This was not Armstrong's
first violation of the Injunction. Prior to that, Armstrong repeatedly
and wilfully disobeyed the preliminary injunction which preceded the
permanent injunction. (Wilson Decl. 2:20-26) I at no time disobeyed
the "preliminary injunction." Between 1992 and 1994 Scientology
attempted to have me sentenced and jailed for several non-existent
"violations" or "contempts" which its agents manufactured. All of the
alleged contempts were discharged, and Mr. Wilson, who participated in
the contempt proceedings, is fully aware of this fact.
23. I sent the declaration and letter, true and correct
copies of which are appended hereto as Exhibit D, to Judge Whyte to
properly report an improper threat received from attorney Wilson. I
had been subpoenaed by defendant Grady Ward to produce documents in
the case of RTC v. Ward, US District Court for the Northern District
of California, case no. C-96-20207 RMW. A true and correct copy of the
subpoena is appended hereto as Exhibit E. The following day I received
from Mr. Wilson a letter, a copy of which is appended hereto as
Exhibit F, threatening "further conflict and annoyance" between me and
Scientology if I produced the subpoenaed documents. I considered and
still consider Wilson's threat to be obstructive of justice and so
reported it to Judge Whyte. I had been threatened by Scientology
lawyers on a number of other occasions when I had earlier been
subpoenaed as a witness in Scientology-related litigations. I am aware
of several legal decisions condemning Scientology for obstruction of
justice, for its policy of using the law to harass and for being a
most vexatious litigant. I have been a target of Scientology's fair
game tactics in the legal arena since 1982 and am very familiar with
those tactics.
24. Mr. Wilson has appended to his declaration as Exhibit
H pages 1, 55 and the proof of service from a declaration I executed
January 26, 1998 and filed in the case of Scientology v. Armstrong,
Marin County California Superior Court Case No. 157680. I am appending
hereto as Exhibit G a true and correct copy of the complete
declaration. A reading of this declaration will reveal that the facts
and truth concerning the October 1995 injunction, my leaving
California and going to Canada, and the contempt orders Scientology
has obtained against me are very different from what Mr. Wilson has
stated about these matters.
25. Mr. Wilson states:
"Accordingly, CSI brought a motion for contempt before
the Hon. Gary W. Thomas in Marin County Superior Court. The Court
issued an Order to Show Cause Re: Contempt on February 18, 1997, and
an Order Allowing Service of the Order to Show Cause Re: Contempt. A
hearing was held on May 23, 1997. Armstrong did not appear, nor did he
file any opposition or evidence." (Wilson Decl. 2:27-3:2)
I was never served with the motion or the OSC.
26. Mr. Wilson states:
"On June 23, 1997, the Marin County Superior Court
entered an Order of Contempt against Armstrong ("Contempt Order") to
punish him for his ex parte communication with United States District
Judge Ronald M. Whyte. The Contempt Order decreed that Armstrong be
punished for contempt..." (Wilson Decl. 3:3-5) For the facts
concerning this improper and illegal contempt order, please see
Ex. G hereto, pp 30-36, paras 35-43.
27. Mr. Wilson states:
"As indicated by the "care-of" return address on the
Armstrong Declaration (Ex. G to Wilson Decl.) cover sheet and the
envelope in which it was mailed, Armstrong - as of December 15, 1997 -
did not have a residential or other address of his own in Nevada."
(Wilson Decl. 21-23) I used, and will continue to use, while I am in
Nevada, my attorney's address for my dealings with Scientology because
of the continual threat from Scientology agents and as a safety
measure against Scientology's false claims of service of documents
when no service had actually been made.
28. Mr. Wilson states:
"On or about April 1, 1998, Armstrong posted a message
(Ex. I to Wilson Decl.) to an Internet public news group stating, "I
have been extremely busy in Canada, and so involved in so many things,
that it has not been ultimately timely to move to my next spot..."
(Wilson Decl. 4:2-4) In that same message, however, I more importantly
state:
"I am not holed up, as you say, although there have
been times when I have been acutely aware of the physical danger I am
in from your organization, which awareness has certainly been at those
times an dominating factor in my behavior. That awareness, peaking
with the discovery of your organization's false IRS 1023, particularly
its black PR of me, was what brought me to leave California and live
the better part of a year in B.C. ś *Within the past few months I
moved my official residence to Nevada,* and that is where I can be
served with legal process. (Underline added) (Wilson Decl. Ex. I)
29. Mr. Wilson states:
"I am informed and believe that, as of
February 14, 1997, plaintiff Gerald Armstrong was living with Lorien
Phippany and residing in San Anselmo, California. On that date, I gave
Mr. Armstrong notice, by telephone to his residence in San Anselmo, of
an ex parte application for the issuance of an order to show cause re:
contempt. The telephone was answered by an answering machine that
played a recording of the voice of Lorien Phippany that stated,
"Please leave a message for either Jerry or Lorien." I called his
number again and heard exactly the same message. śI am informed and
believe that at some point after the Contempt Order and bench Warrant
against Armstrong were issued, Armstrong became a fugitive from
justice by fleeing California for Canada, where he could not be
prosecuted pursuant to the Bench Warrant and Contempt Order. My belief
is based on the fact that on August 25, 1997, he served his opening
brief in the appeal by mailing it from Chilliwack, B.C., Canada.
(Wilson Decl. 4:7-17)
I left California for good and was in Nevada on or about January 28,
1997, and I was in Canada on February 11, 1997. Appended hereto as
Exhibit H is a true and correct copy of my boarding pass of that date.
The contempt order Mr. Wilson refers to was not issued until June,
1997. I stayed in Canada until October, 1997 when I traveled to
Germany. After returning to Canada from Germany I traveled to Nevada
where I established my present residence in November, 1997.
30. Mr. Wilson states:
"I mailed a copy of said motion, referred to by
Armstrong in his declaration, to Armstrong at his last known
residential address in San Anselmo, California in early November,
1997." (Wilson Decl. 5:19,20)
This is untrue. This motion was mailed by Mr. Wilson to me in Nevada.
It was never, to my knowledge, mailed to my former address in
California, and I did not receive it there, nor was it forwarded to me
from there.
29. Mr. Wilson states:
"In January, March and April 1998, I caused Sheila M.
Werner of Vancouver, British Columbia, Canada to establish contact
with Gerry Armstrong by telephone by telephone and in person. During
this time period, as testified to be Ms. Werner, at Exhibit L, she had
contact with Gerry Armstrong on 10 separate occasions. Each time Gerry
Armstrong was in Chilliwack, British Columbia. In a personal meeting
on April 5, 1998 Gerry Armstrong informed Ms. Werner that he had
recently been in Nevada "but that he does not plan to live there and
was only there for legal matters." (Wilson Decl. 5:21-26)
As I have stated in paragraphs 10-19, supra, Ms. Werner is simply
lying about what I told her concerning my Nevada residence and my plan
to live here. While it is true that each time Ms. Werner contacted me
I was in Chilliwack, B.C., she could just as easily have contacted me
in Nevada. Since she was, according to the sworn statement of attorney
Wilson, being directed and operated by him in this operation, he could
just as easily have had her call my attorney George Abbott, with whom
Mr. Wilson has corresponded a number of times, to reach me in Nevada.
She knew that I was in Nevada during March this year, and I have been
very open about my being here and planning to be here. Mr. Wilson sent
Ms. Werner to get close to me by lying about her intentions and her
contacts with Scientology agents in order to give a context to the lie
he wanted her to tell about my intention to live in Nevada.
30. Mr. Wilson states:
"On April 15, 1998, in an attempt to determine whether
Armstrong has as yet acquired a residence in Nevada, I telephoned
information at (702)555-1212 and inquired as to a listing for Gerald
Armstrong in Minden, Nevada, or anywhere within the 702 area code. The
operator with whom I spoke informed me there was no such listing."
(Wilson Decl. 5:27-6:2)
I have no intention of having a listed telephone number and do not
have one. A search will also reveal that there is no listing for me in
Canada.
31. Mr. Wilson states:
"On the basis of the aforementioned events, I am
informed and believe that at the time of the filing of the complaint
in this case and continuing until the present time, Armstrong was
still residing in Canada." (Wilson Decl. 6:4-6)
This is untrue. I did reside in Canada during part of 1997. Members of
my family still reside there, and I may still visit them there from
time to time, but my residence is now here in Nevada and I intend to
stay here.
32. CSI avers that "there is no basis for the Court to assert
personal jurisdiction over Defendant CSI because there are no contacts
between Defendant and the State of Nevada." (CSI's Motion, 2:9-10) On
information and belief, this averment is completely untrue. CSI is a
"management" component of the Scientology enterprise, managing all the
"lower level " Scientology organizations around the world, including
Nevada. There is a "lower level" Scientology organization, the "Church
of Scientology of Nevada," located in Las Vegas, as well as even lower
level franchises, which are also under the control of CSI. CSI
"management" personnel have continual contact with personnel at the
Nevada organization, and in fact control the Nevada corporation's
activities. CSI is made up of Sea Organization ("SO") members, the
"elite" upper echelon of Scientology management staff who are required
to sign billion year service contracts. Control of all of Scientology,
including Scientology in Nevada, is effectuated through SO members and
SO organizations including this moving defendant corporation. CSI
sends its personnel on "missions" to every lower level Scientology
organization in the world, including Nevada. These "missionaires", and
CSI itself, have the authority to issue orders to any personnel in any
lower level Scientology organization in the world including Nevada,
and enforce compliance with those orders. Enforcement powers of CSI
over personnel in every lower level Scientology organization including
Nevada are unlimited and can include staff position changes, dismissal
and fair gaming. CSI, under the ultimate control of supreme
Scientology leader David Miscavige, is in control of the finances of
every lower level organization in the world, including Nevada, and
derives income from its management and control of those lower level
organizations including Nevada.
33. CSI also now "licenses" Scientologist around the world
with an Internet account, including Scientologists in Nevada with an
Internet account, to have a personal web site designed with a template
provided by CSI. A true and correct copy of the "contract" between CSI
and Scientologists, including Scientologists in Nevada is appended
hereto as Exhibit I.
34. CSI director Michael Rinder states:
"CSI has no offices or subsidiaries in Nevada. It is
not qualified to conduct business in Nevada and it does not conduct
business in Nevada." (Rinder Decl. 2, para 3)
This is untrue. On information and belief CSI conducts business
continually in Nevada. Mr. Rinder has been for some time the head of
Scientology's Office of Special Affairs International ("OSA Int"), the
branch of the global Scientology enterprise dealing with "legal
affairs," "public relations" and "intelligence operations." OSA Int is
"housed" in CSI. Each lower level Scientology organization around the
world, including in Nevada, has its own OSA unit, under the direction
and control of OSA Int. OSA Nevada personnel are trained at OSA Int,
posted to their Nevada OSA positions by OSA Int, directed and operated
on orders from OSA Int, and may be removed from their positions and
punished by OSA Int.
35. I know Mr. Rinder personally. He is himself a
Scientology intelligence operative who participated in a 1984
intelligence operation against me with the goal of entrapping me in
the "commission" of a crime. Mr. Rinder pretended to be a critic and
reformer of the Scientology organization's criminal activities in
order to lure me into a setting and conversation where I was covertly
and illegally videotaped. This illegal videotaping involving Rinder,
which was denounced by the then Chief of the Los Angeles Police
Department, is central to my claims of defamation in this case. Rinder
has also personally participated in fair game and black PR operations
against me following the 1984 operation.
36. RTC avers that "there is no basis for the Court to assert
personal jurisdiction over Defendant RTC because there are no contacts
between Defendant and the State of Nevada." (RTC's Motion, 2:6,7) On
information and belief, this averment is completely untrue. RTC is a
component of the Scientology enterprise by which David Miscavige, as
Chairman of RTC's Board of Directors, head of the Sea Organization,
and Scientology supreme leader, is able to control all Scientology
organizations, including the Nevada Scientology organization, and all
Scientologists around the world, including all Scientologists in
Nevada. RTC claims to own or control Scientology's various trade and
service marks, and to own or control Scientology's texts, policies and
other writings. RTC licenses "lower" Scientology organizations,
including the Nevada Scientology organizations, to use the marks and
copyrighted materials it owns or controls. RTC controls, through CSI
management or missionaires, what is done in every Scientology
organization in the world, down to the most minute details. RTC owns
or controls the term "Scientologist" and determines and controls who
is a "Scientologist in good standing" around the world, including in
Nevada. RTC has continual contact with personnel at the Nevada
organization, either directly or through CSI, and controls the Nevada
corporation's activities through licensing contracts and through CSI
management and other components of the global Scientology enterprise
control. RTC, like CSI, is made up of Sea Organization ("SO") members.
Control of all of Scientology, including Scientology in Nevada, is
effectuated through SO members and SO organizations including this
moving defendant corporation. RTC, like CSI, sends personnel, either
its own, CSI's or from some other SO component of the global
Scientology enterprise, on "missions" to lower level Scientology
organizations, including Nevada. These "missionaires", and RTC, either
through CSI or by itself, has the authority to issue orders to any
personnel in any lower level Scientology organization in the world
including Nevada, and enforce compliance with those orders.
Enforcement powers of RTC, as with CSI, over personnel in every lower
level Scientology organization including Nevada are unlimited and can
include staff position changes, dismissal and fair gaming. RTC derives
income from its licensing activities and its management and control of
lower level organizations including Nevada.
37. Appended hereto as Exhibit J is a true and correct
copy of an Order filed October 29, 1997 in the case of Lawrence
Wollersheim v. Church of Scientology of California, et al., Los
Angeles Superior Court Case No. C332027, and an Order Amending
Judgment and Judgment Thereon filed November 14, 1997 in that case.
The Los Angeles Court stated in its Order:
"The parties agree that Scientology reorganized its corporate
structure from 1981 through 1985, during the pretrial stage of the
instant lawsuit. CSI became the new "mother church," replacing CSC.
RTC was formed in 1982 with the approval of L. Ron Hubbard,
Scientology's founder, and is the owner and protector of Scientology's

service marks and products." (Ex. J, p 2, para 3)
"Authority over CSC and its affairs was handed over to
CSI and RTC, especially David Miscavige, who controls both
corporations and all of Scientology after the death of L. Ron Hubbard.
"Sea Org" is the unincorporated association which is the power center
- Miscavige is its highest ranking member. [ ] Miscavige is also
Chairman of RTC [ ]" (Ex. J, p 4, para 9)
"Scientology's corporate officers and trustees are
intermingled at will." (Ex. J, p 4, para 10)
"RTC's present chairman and highest officer in the
power hub "Sea Org," David Miscavige, supervised and controlled the
defense [of the Wollersheim litigation]" (Ex. J, p 5, para 14)
"As this court has concluded CSI and RTC are the alter
egos of CSC [ ]" (Ex. J, p 6, para 5)
38. The CSI-RTC-Sea Org power hub of Scientology under
David Miscavige employs agents who use the Internet to black PR
critics and reformers of the organization's immoral activities. These
agents post attacks on critics and reformers, including me, on various
newsgroups, especially alt.religion.scientology ("ars"). These black
PR attacks go to every country and every state, including Nevada. I
have today downloaded at a computer terminal in Nevada a
representative sample of the hundreds of posts Scientology agents have
made to ars and other newsgroups attacking me. A true and correct copy
of these representative posts are appended hereto as Exhibit K. All
these posts, and many more black PR attacks on me are available to
anyone in Nevada at URL http://www.dejanews.com.
39. Appended hereto as Exhibit L are true and correct
copies of pages from the book What is Scientology? The copyright page
states that the book was "Compiled by the staff of the Church of
Scientology International." Page 358 and 359 are descriptions for
Scientology public relations purposes of CSI and RTC respectively.
40. Included in the description of CSI are the following
statements:
"Through CSI's ecclesiastical management activities,
individual Scientology churches receive guidance in applying the
scriptures both technically and administratively.
CSI broadly plans and coordinates Scientology
expansion overall; providing programs to be carried out by the
individual organizations and groups, and then helping with their
implementation toward expansion.
...
In addition to coordinating the overall expansion of
Scientology, CSI sees to the distribution of Scientology scriptures,
both in written and audiovisual form.
...
Church management provides ecclesiastical guidance to
each of the Scientology organizations, coordinates the activities and
expansion of Scientology internationally and in so doing makes it
possible for Dianetics and Scientology to meet the demand for its
services around the world." (Ex. L, p. 358)
Among the organizations or groups that CSI manages and coordinates the
activities of are the Scientology organizations and groups in Nevada.
Among the locations in which CSI sees to the distribution of
Scientology written and audiovisual scriptures is the State of Nevada.
41. Included in the description of RTC are the following
statements:
"RTC possesses ultimate ecclesiastical authority over
the international hierarchy concerning the maintenance and standard
application of L. Ron Hubbard's technology. RTC owns all the
Scientology trademarks and service marks and controls their licensing
and use." (Ex. L, p 359)
Within the "international hierarchy" over which RTC possesses ultimate
authority are the Scientology organization and groups located in
Nevada. Among the organizations and groups wherein RTC controls the
use of the trademarks and service marks are the Scientology
organization and groups in Nevada. Among the organizations and groups
wherein RTC has authority of the application of Scientology
"technology" are the Scientology organization and groups in Nevada.
42. CSI states:
"Armstrong is proceeding in Nevada so that he may
avoid the consequences of the contempt order in California, and this
Court should not permit its jurisdiction to be invoked so that the
jurisdiction of another court may be subverted and the Complaint
should therefore be dismissed." (CSI's Memorandum of Points and
Authorities, 10:14-17)
This is untrue. The consequences of the California order, although
that order is illegal and a part of Scientology's ongoing fair game
campaign against me, have nothing to do with my choosing Nevada as my
residence. During another period when I was working at a completely
different job in Nevada in 1996 I became acquainted with attorney
George Abbott who now represents me in this case. Over the next
several months I communicated many times with Mr. Abbott, and he
became familiar with my history and with Scientology's unrelenting
attacks on me, including its use of the courts to carry out its
improper attacks. My history of attacks at Scientology's hands is long
and my legal situation with Scientology is complex, and I was grateful
to find in Mr. Abbott an attorney who both understood these matters
and had the courage to want to do something about righting the
injustices Scientology was heaping on me. This is what brought me to
decide to move to Nevada in order to work with Mr. Abbott. My moving
to Nevada has nothing to do with avoiding legal consequences, but is
to facilitate my being able to correct Scientology's injustices. My
move to Nevada could not be arranged any earlier than I did for
various personal reasons, but as soon as I was able to do so I did
make Nevada my domicile, and took the first step to correct
Scientology's injustices by filing this lawsuit.
43. I left California in January, 1997 not as a fugitive
from justice, but to be able to correct a terrible injustice. I
discovered in January, 1997 that, in addition to Scientology's
continuing to black PR me publicly, e.g., as shown by the black PR
provided to Watchman Fellowship which underlies this case, and in
addition to continuing to threaten me in and out of the legal arena,
the organization had also included a terrible black PR attack on me in
its form 1023 submission to the IRS, pursuant to which Scientology's
1993 tax exemption was granted.(See also 1/26/98 declaration, Ex. G
hereto, pp 20-23, paras 27, 28). I realized when I read that black PR
provided to the IRS that Scientology's leaders believed that their
fraudulently obtained tax exemption, involving perhaps billions of
dollars, depended on silencing me, and that I was in extreme danger.
That danger, and the need to be somewhere relatively safe where I
could do something relatively safely to reduce that danger and expose
the underlying fraud, is what brought me to leave California, to go to
Canada, and finally to move to Nevada where I am working with Mr.
Abbott to correct these wrongs. I am not a fugitive from justice, but
am actively involved in Nevada in rectifying the injustice of the
California injunction, and the subsequent "contempt orders" which
Scientology was able to get the Marin County California Court to sign.
44. I am more certain than ever that the orders of the
Marin Superior Court, upon which the Scientology defendants herein
rely to claim that I am a fugitive from justice, and to support their
motion to dismiss this case, impermissibly violate the US
Constitution's guarantees of First Amendment freedoms, are against
public policy and illegal. I can no more be legally judicially
compelled to not mention L. Ron Hubbard, Scientology or my experiences
in that "religion" than another US citizen can be legally judicially
compelled to not mention, on penalty of fine and imprisonment, God,
Jesus Christ, the Christian religion, or the person's religious
experiences in that religion. I do not believe that the right to
discuss a religion or religious experiences or reform a religion can
legally be contracted away or judicially prohibited and punished. I am
certain that the Marin Court's order, which Scientology interprets to
permit that organization and its agents to say or publish whatever
they want about me, and prohibit me from responding or punish me with
fines and imprisonment if I do respond, is against public policy,
obstructive of justice, and illegal. This interpretation by
Scientology is articulated in a letter dated February 25, 1997 from
attorney Wilson to my attorney George Abbott, a true and correct copy
of which is appended hereto as Exhibit M. Mr. Wilson states in that
letter that I am not free "to communicate orally, in writing or by any
other legal means available to [me] to fully correct [ ] alleged lies
and distortions." (Ex. M p.1, para 3). The Scientology organization
leaders and their agents have subjected me for over fifteen years to a
massive international black PR assault on my character, credibility,
safety and peace. I cannot believe that I can, in this country, be
legally prohibited from defending myself. I cannot believe that our
justice system will continue to permit this modern day slavery.
I declare under the penalty of perjury under the laws of the
United States and the State of Nevada that the foregoing is true and
correct.
Executed at Minden, Nevada on May 6, 1998.

GERALD ARMSTRONG

[Pimoty]

Keith: You are the best practitioner of "black dianetics" Gerry.>>

Accusing again when unable to confront dear Keith.

+++
For additional info:
http://www.xenu.net
http://www.entheta.net
http://www.lermanet.com/cos/yanny.html

[Pimoty]

Gunbunny: I'm glad to see that the ARSCC OPS has sent someone to handle me. Who
pays you and what is your crime?>>

My crime is passion and my payments are satisfaction.