I, VAUGHN YOUNG, declare as follows:

I am a published author and a writer by profession. For the past 13 years, my area of expertise is what is generally known as "investigative reporting." I have mainly concentrated on federal agencies including the CIA, FBI, IRS, and the Army. In that capacity, I testified twice before Congressional subcommittees as an expert on INTERPOL which was the subject of a book that I co-authored ("THE INTERPOL CONNECTION", Dial Press, 1979). To research that book, I traveled to seven countries, obtained about 50,000 pages of material from the government under the Freedom of Information Act and interviewed hundreds of people in the U.S. and across Europe.

In the latter part of 1981, I was asked by the church to assist in sorting out problems on the proposed biography of L. Ron Hubbard. I was asked to do this because I knew Omar Garrison and I was also a writer and would understand the situation.

In that capacity, I moved to the archives where Gerry Armstrong worked at the end of October, 1982. I was there when Armstrong left the church and was actually the last person to see him. After he left, I took over the archives and thus I had an opportunity to see the "fruits" of his efforts.

During those two months with him, I was virtually the only person working with him. Thus I had many occasions to talk with him about Mr. Hubbard, the documents in the archives and research. I also read thousands of documents and became familiar with them and Armstrong's work. I did so because, as stated earlier, research has been one of my professional skills.

There is no doubt that Armstrong's "research" was tacky, shoddy, inept and simply malicious. When I tried to advise him on what should be done, he would either do it wrong, get it confused or he would simply refuse.

Let me cite a key example: Armstrong was interested in one "Snake" Thompson that Mr. Hubbard had cited in a number of works. Mr. Hubbard had said that Thompson had taught him Freud. Armstrong suspected that there was no Thompson. One of his reasons was that Mr. Hubbard never gave Thompson's first name but always used the "Snake" nickname. In November, 1981, Armstrong showed me a document from Mr. Hubbard's naval file that had the name and signature of a "Thompson". He said he wondered if this was "Snake" Thompson. I told Armstrong it would be a very easy task to trace the Thompson on the document and told him how to do it. However, he just shrugged and said he wasn't interested and put the document back. Later, in his own court case, he then repeated the accusation (that there was no "Snake" Thompson) and claimed he had "researched" the matter. This is a lie and he knows it. He turned his back on this.

After Armstrong left the church, in my own research, I found that the Thompson in the document was not "Snake" Thompson. However, I did confirm the existence of "Snake" Thompson (now deceased) as Joseph Cheesman Thompson. I also confirmed every statement that Mr. Hubbard made about him right down to a trip they made from San Francisco and through the Panama Canal in 1923 by finding the passenger list of the ship. I am providing copies of Thompson's birth certificate, a cover note from the Department of Health and Human Services about an article Thompson wrote on psychoanalystic literature and the passenger list just cited.

Before Armstrong knew that I had confirmed this information, he said that Mr. Hubbard's claim about "Snake" Thompson was an example of how Mr. Hubbard lied. Armstrong even claimed this in court, under oath. I was called to testify on the matter and I did so, presenting documentation to refute Armstrong's claim about Thompson's alleged non-existence and other biased falsehoods in Armstrong's claims about Mr. Hubbard.

There are other examples of Armstrong "research" that show that much of his supposed ineptitude was simply malice, but I cite this one because Armstrong specifically raised it with me and I specifically told him how to handle it and he refused. I now see why. He was afraid that he would prove Mr. Hubbard right. I also cite it because this was the "research" Armstrong provided Garrison and the two of them shared the same attitude -- anything that did not substantiate their bias was refused.

In short, Armstrong was not a "researcher" by any professional standards. He was nothing more than a shoddy clerk. On the surface; he gathered a lot of documentation but even that was gathered mainly by others who simply sent it to archives. Armstrong was merely there to take it in. He made it appear that he went out and collected thousands of documents when what he did was take in what others sent. He told this to me himself, how people would clean out an area, find some documents and ask where to put it and because someone would say "archives", it would come to him. That is not "research."

Nor did he have an ability to follow up on information and that is where the professional boundry occurs. I spoke with him about these documents and he admitted that he did not know them. Specifically on the naval documents alone:

1. He did not look at the code numbers on government documents to differentiate their types or origins,

2 . He did not follow on the identity of those who wrote them and determine their position,

3. He did not place them into a historical context to see what was happening,

4 . He did not bother to sort out military chains of command or theatres or enemy movements during the Second World War and place the documents and their dates against them. (I am attaching samples of some of the documents that verify these other theatres.)

In short, his "research" was superficial, glib, shallow and flippant, not to mention that he interpereted everything through his own foolish bias, prejudice and animosity.

Another key example of Annstrong's amateurish inneptitude deserves to be cited since he was the source of Garrison's data on Mr. Hubbard.

Armstrong delighted in citing how Mr. Hubbard was "busted" from a command in Australia in early 1942. Yet he failed to take into account that Mr. Hubbard was Naval Intelligence, specifically counter-espionage, and that Mr. Hubbard's assignment to Australia was for this purpose.

Anyone familiar with basic military procedure would know that when an officer is "busted," he is DEMOTED in command. That comes with the definition of "busted." You don't "bust" an officer from a desk job to command of a ship. That would be a PROMOTION. Yet that is exactly what happened to Mr. Hubbard. When he was "busted", he was given command of a ship a few months later. That is a sign of an OFFICER UNDER COMMAND OF INTELLIGENCE and that is borne out by the documents in Mr. Hubbard's files.

Armstrong did not have the vaguest idea that the files of intelligence officer are "sheepdipped" (a term that basically means that they are tampered with and cleaned to cover the actions and perhaps even the identity of the officer). Frankly, he was barely able to read the file, let alone understand it. (I am attaching a copy of an affidavit from L. Fletcher Prouty who explains the "sheepdip" process that was used in the intelligence services.)

Another example was Armstrong's claim that Mr. Hubbard "never saw action." Yet after Armstrong was purged from the church, competent researchers found Mr. Hubbard's former Executive Officer (Thomas Moulton) from one of Mr. Hubbard's ships, the PC 815, who presented under oath the declassified Action Report of the ship in combat with at least one enemy submarine and testified about the battle. I am attaching a copy of that Action Report.)

During the trial of Armstrong for theft of church documents and Mr. Hubbard's private papers, Armstrong was unable to refute any of this documentation.

In other words, when one inspected Armstrong's work closely, he was shown to be an incompetent amateur and a liar.

Since he left the church, documentation that Armstrong refused to find has been gathered by the thousands and thousands of pages. People have stepped forward to refute Armstrong's hallucinations.

This is the quality of "research" that I found was being done for the biography.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 12th day of May 1985, at Los Angeles, California.


Vaughn Young