------------------------------------------------------------------- F.A.C.T.Net, Inc. (Fight Against Coercive Tactics Network, Incorporated) a non-profit computer bulletin board and electronic library 601 16th St. #C-217 Golden, Colorado 80401 USA BBS 303 530-1942 FAX 303 530-2950 Office 303 473-0111 This document is part of an electronic lending library and preservational electronic archive. F.A.C.T.Net does not sell documents, it only lends them according to the terms of your library cardholder agreement with F.A.C.T.Net, Inc. ------------------------------------------------------------------- \Scarff declaration & comment\Page.00001 GARRY L. SCARFF 2137 N.E. Weidler Street Portland, Oregon 97232 (503) 281-9088 May 25, 1993 Margery, In my deposition with the Cult Awareness Network, I questioned the personal and professional integrity of Ford Greene, in the manner which he represented me as a lawyer. The attached declaration is a good example. The content of this declaration resulted from a 4-hr. long distance telephone call which Ford assured he would pay for, but later refused. It had gone through several revisions because Ford was compelled to use it as a means to air his personal opinions. Eventually, I signed a declaration. However, to my dismay, which was brought to my attention by Dan Leipold, Ford has taken pages from earlier declarations which I did not approve of, and submitted them with the declaration I signed. When I ordered Ford to retract the declaration, he laughed and said he had already submitted to the court. You will observe one of the pages ~4, lines 17-21, in which Ford denigrates you. The remark "history of mental instability" was omitted from the declaration that I had signed. Because of this, and other events, I no longer have any association with Ford and have refused to be a defense witness in Gerry Armstrong's case as long as Ford remains his attorney. Garry Scarff \Scarff declaration & comment\Page.00002 1 HUB LAW OFFICES . Ford Greene, Esquire 2 California State Bar No. 107601 711 Sir Francis Drake Boulevard 3 San Anselmo, California 94960-1949 Telephone: (415) 258-0380 4 Attorney for Defendant S GERALD ARMSTRONG 6 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF LOS ANGELES 10 11 CHURCH OF SCIENTOLOGY ) No. BC 052395 INTERNATIONAL, a California 12 not-for-profit religious ) DECLARATION OF GERRY L. SCARFF corporation; IN SUPPORT OF OPPOSITION TO 13 ) MOTION TO COMPEL Plaintiffs, ) 14 vS. Date: February 19, 1993 15 ) Time: 8:30 a.m. GERALD ARMSTRONG: DOES 1 Dept: 30 l6 through 25, inclusive, ) ) Trial Date: May 3, 1992 17 Defendants. ) Discovery Cut-Off: None ) Motion Cut-Off: None 18 19 GARRY ~. SCARFF declares: 20 1. My na~e is GWUiY L. SCARFF. I live at 213~ N.E, Weidler 21 St,, Partland, oregon 97232. My ~elephone number is (~03) 281- 22 90B8~ I am above ~he age of eightsen years old and provide the 23 iollowing ~estimony of my own firs-~~hand knowledge. I could and 24 would provide the same testimony in open court were I required to 25~ do so. 26 2. From 1982 through August 1942, ~ was a member of the I 27 CHURCH OF SCIENTOrX)GY. For the two years preceding 1992 L was an 28 aperative of SCIENTOtOOY in the Los Ange~es area where r have \Scarff declaration & comment\Page.00003 1 worked closely with EUGENE 1NGRAMI a licensed priva~e investigator 2 whose income is salely derived from SCIENTOrX~GY. 3 3. EUGENE INGRAM, at the directian of SCIENTOMGY, hhs 4 attempted to ruin FOrU) GREENE on a personal and professional basis 5 because of his activities on behalf of the Cult Awareness Network, 6 his outspoken and public criticism oe SCIENTOLOGY, hi6 7 representation oe earmer Scientologis~s, par~icularly Richard and 8 Vicki Aznaran, and his current working relationship w~th GERALD 9 AfZMSTRONG, a fonner high-ranking Scientologist~ 10 4. The operations against FORD GREENE are coordinated 11 through the CITURCH OF SCIENTOLOGY INTERNAT~ONA~ in Los Angeles. 12 ~n ~his regard, I knew ~ha~ the person who directed and controlled 13 ~hese operations was DAVXD Ml$CAVIGE, the head oE Scientology. 14j 5. In 1987 I was directed by SCIENTOLOGY to represent 15 mysele as a survivor of the People's Temple in~nofation in 16 J~nes~own, Guyana and befriend FORD GREENE in order to perpetrate 17 a Sciantology operation on him. During Christmas 1987 FORD 18 invited me ~o spend the holiday with hi~. When I was in his 19 office alane during that periad af time, I availed mysalf af his 20 confiden~ial Legal records, legal Piles of his clients, a rolodex 21 oS his contacts and photographed his office. 22 6. In approximately Sep~e~nber 1991 at a McDonhld's 23 ~estaurant located in Albany, Oregon, EUGENE 1NGRAM showed me a 24 letter ~o the Federal Bureau of Invss~iga~ion which I read. The 2~ lettey fro~ INGRAM stated that FORD GE~EENE was involved in the 26 ~rafficking of drugs and the misuse of his law office by trading 27 homosexual favors for the rendering of lega3 services. I~GRAM 28 frequently discussed his desire to have FORD GREENE indicted under \Scarff declaration & comment\Page.00004 1 tbe RICO statutes. 2 7. On or about December 20, 1991, I attended a meeting at SC~ENTOMCY's OFFICE OF SPECIAL AFFAIRS in Los Angeles where the 4 law offices of BOWLES and MOXO~ are located. Present at that 5 meeting were the following individuals: KENDRICK MOXON, TIMOTHY 6 BOWLES, RANDY SPENCER and ~LC~IPBPNI all oP whom are attorneys at 7 Scientology's in-hause law firrs, BOWLES AND MOXON. ~lso pr~s~nt 8 were EUGENE INGRAM, and DAVID BUTTERWORTH, the director of 9 Scientology's OFFICE OF SPECIAL AFFAIRS. One purpose of this 10 meeting was to develop a plan to destroy the personal and 11 professional credibility of FQRD GREENE and t4 continue alCempts 12 to have him disbarred from practicing law because he represented 33 litigants against SCIENTOLOGY. 1 14 The operations that were proposed and developed at this 15 meeting included the following: 16 a. Ta create a public scheme portraying FORD GREENE as a 17 sex fiend. This was ta be accomplished through EUGENE INGRAM's i 18 manipulation of Margery Wakefield, a former client of FORD GREENE 19 with a history of mental instability. INGRAM was to go to Florida , 20 and dupe Ms, Wakefield into signing a declaration that would be 21 detrimental ~o FORD GREENE. 22 b. INGR~ asked me to execute a declaration stating that 23 when I stayed with FORD Gr~EENE over the Christmas holidays in 1987 i 24 Ford induced me to get drunk on alcohol and stoned on marijuana at : 25 which ~ime INGRaM told me to s~a~e ~hat FORD sodomized me and 26 forced me to orally copula~e bim. INGRAM also told ~e ~o s~ate 27 that 1 did not admit to this in an earlier (ealse) declaration 28 because FORD was to have threatened to send his drug dealer \Scarff declaration & comment\Page.00005 1 contacts to kill me if I stated anything of the homosexual a~tack. 2 c. INGrZAM also wan~ed me to swear that FORD GREBNE wag a 3 paying and frequ~nt palron of a San Francisco bathhouse, that FoRo 4 GREENE was infectea with the AIDS virus, and was intentionally 5 passing it to otheys, 6 d. IfJGEZAM also SOUgh~ to expand on wha~ he called the 'fuck 7 buddy~ relationship between FOrr~D GREENE and GERAL~r) ARMSTRONG. One 8 af rNGRAM's suggestions was to set FORD GREENE up with a new male 9 client ~ho then wo~ld provide a declaration swearing that G~ZEENE 10 agrsed tb barter his legal services in return for sex. 11 Rns.J~ Another of 1NGRaM's suggestions was tha~ ~ go to San 12 and break into and enter GREENE's office when he was no~ i 13 present and plant cocaine and child POrnography in his desk and 14 ~hen advise ~he police of GREENEIs illegai possessions. 15 f. Xngram alsd ~uggested tampering wi~h FORD CREENEls auto~obile by severing its brakes lines in order ~o produce a 17 s~rious accident. When ~ said to Ingram that it could alsa kill 18 GREENE, INGRAM responded, "There's no loss in a dead fag.' INQRAM 19 also suggested orchestrating an accident involving GREENE an the 20 Golden Gate Bridge that would result in GREENE's car go~ng ovey 21 the side of the Bridge, 22 g. INGRI~3 and SCIENTOr~OGY have also attempted to have 23 GREENE disbarred by filing complaints with the State Bar. 24 8. At the instigation of EUGENE 1NGRAM, DAVID BUTTEE~WO~TH 25 and the aforementioned attorneys in BOWLES AND MOXON I have 24 executed declarations in tJhich I made false statements of fact. 27 With respect to FORD GREENE, the false statements of fact that I 28 made included, but were not limited to, the \Scarff declaration & comment\Page.00006 1 a. FORD GREENE is a homosexual. The truth is I have no 2 basis for this statement; 3 b. FORD GREENE frequented the Castro Street area (a gay 4 area) in San Francisca. I have no factual basis for this 5 statement; 6 c. While nude FORD GREENE hugged me and would not let go. 7 This is false. 8 d. GREENE took a picture of me, naked, as I was leaving the 9 shower. This is false. 10 9. INGRAM, BUTTERWORTH and lawyers at BOWLES AND MOXON 11 repeatedly expressed that they would do anything to prevent GERALD 12 ARMSTRONG a~d FORD GREENE from working togethe~. 13 Pursuant to the laws oE the State of California, I hereby 14 declare the eoregoing to be Irue and correct. Executed on 15 February 11, 1993 at Par~lana, Oregon. 16 17 GARY L. SCARFF 18 19 20 21 22 23 24 25 26 27 28 ================================================================= If this is a copyrighted work, you are acknowledging by receipt of this document from FACTNet that on the basis of reasonable investigation, you have not been to obtain a copy elsewhere at a fair price, and that you are and will abide by the following copyright warning. WARNING CONCERNING COPYRIGHT RESTRICTIONS: The copyright law of the United States (Title 17, United States Code) governs the making of photo copies or other reproductions of copyrighted material. 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