I, Lynn R. Farny, do declare:
1. I am over 18 years of age and make this declaration of my own personal knowledge and for those matters stated upon information and belief, I believe them to be true and accurate. If called as a witness to testify as to the matters herein, I could and would do so competently.
2. I am corporate Secretary of the Church of Scientology International (“CSI”), a California religious corporation.
3. I have reviewed the photographs which are attached to the declarations of Sam Brown and Thorn Smith, Exhibits D and I to the Supplemental Memorandum in Support of Motion to Dismiss the Complaint. I recognize the individual in the photographs attached to the Smith declaration as John Koresko and the individual in the photographs attached to the Brown declaration as Gerald Armstrong.
4. I am well familiar with Gerald Armstrong, as I have worked in the legal department of CSI since 1984, and prior to that in the legal department of Church of Scientology of California (“CSC”). I have actively followed the events occurring during that time in lawsuit against Gerald Armstrong by CSC regarding his theft of private documents belonging to the Founder of the Scientology religion.
5. I am also well familiar with John Koresko, who was office manager and later a paralegal for Joseph A. Yanny, CSI’s former attorney, during the time that Yanny represented
CSI and afterwards, when CSI and CSC sued Yanny for his breaches of fiduciary duties.
6. That Armstrong is amenable to the kind of covert representation in which Yanny is engaging in this case is highlighted by his recorded remarks made in November 1984. At that time, Armstrong was plotting against the Scientology Churches and seeking out staff members in the Church who would be willing to assist him in overthrowing Church leadership. The Church obtained information about Armstrong’s plans and, through a police-sanctioned investigation, provided Armstrong with the “defectors” he sought. On November 30, 1984, Armstrong met with one Michael Rinder, an individual whom Armstrong thought to be one of his “agents” (but who in reality was loyal to the Church). In the conversation, recorded with written permission from law enforcement, Armstrong stated the following in response to questions by Mr. Rinder as to whether they had to have actual evidence of wrongdoing to make allegations against the Church leadership:
ARMSTRONG: They can allege it. They can allege it. They don’t even have — they can allege it.
RINDER: So they don’t even have to — like — they don’t have to have the document sitting in front of them and then —
ARMSTRONG: Fucking say the organization destroys the documents.
* * *
Where are the — we don’t have to prove a goddamn thing. We don’t have to prove shit; we just have
to allege it.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed in Los Angeles, California the 26th day of August 1991.
[signed] Lynn R. Farny
LYNN R. FARNY