CHURCH OF SCIENTOLOGY OF CALIFORNIA,
        Plaintiff,
    vs.
GERALD ARMSTRONG,
        Defendant.
MARY SUE HUBBARD,
        Intervenor.
           
   

[...]
     Q [by MICHAEL FLYNN] Turning now to exhibits 6E through 6Q which we

went through quickly yesterday which called for -- which

recited in Mr. Hubbard's handwriting that among other things,

he should find the unsavory part of a person's past and the

criminal activities of a person's past and pursue for

harassment and items of that nature, when you sent those to

me did you correlate the statements of Mr. Hubbard in those

documents to statements that he had made in what has been

marked exhibits 500 4D through 4G?
 

    MR. LITT: Objection, Your Honor.

    THE COURT: Overruled.

    THE WITNESS: Those 4D through 4G are the documents

that we have called at various times the affirmations or the

admissions, and there are some parts of those documents which

were very significant to me, having to do with --

    MR. LITT: Just a moment.

    MR. FLYNN: Well, before you get into this, Your Honor,

I'm going to do this on a very step-by-step basis, and then

I will lay the foundation, and then I will inform the court

of just several lines in the documents that correlate to

these documents which the witness found extremely significant.

    Q Now, did you find several statements by Mr. Hubbard

in exhibit 4D through 4G that correlated to statements he

had made in the 1960's pertaining to attacks on enemies and

the Fair Game Doctrine?

    A Yes.

    Q And those statements are in exhibits 4D through

4G; is that correct?

    A Yes.

    Q And what was your state of mind, Mr. Armstrong,

when you found the documents in the 1960's in Mr. Hubbard's

handwriting relative to attacking enemies?

    THE COURT: Maybe you better identify what are you

referring to now? Is this something in the 6 series?

    MR. FLYNN: In exhibit 6.

    THE COURT: Try to be a little more specific.

    Q BY MR. FLYNN: 6E through 6Q.
    

    Now, in 6E you testified that Mr. Armstrong wrote

about finding the criminal part or past of a particular

individual; is that correct?

    A Yes. It was Mr. Hubbard, yes.

    This was a woman whose daughter had disconnected

from her pursuant to Scientology policy, and Mr. Hubbard had

ordered legal officer Branch 5 to investigate her past and

psychiatrists' past and find the criminal part -- criminal

past of these people.

    Q Now at that time were you familiar with the Fair

Game Doctrine that has been marked as an exhibit to lie, sue,

cheat, and destroy enemies?

    A Yes.

    Q And in several other exhibits in Mr. Hubbard's

handwriting, did you find similar statements about finding

the unsavory side of their past with reference to enemies?

    A Yes.