I, Ford Eartin Schwartz, of 825 Oak Grove Road, 
concord, California, hereby depose and state under the pains 
and penalties of perjury as follows:  

. / 
1)  This affidavit is based upon personal know-aE2 also upor: .information and belief where so stated. 
ledae 
 
2!  In spring, 19B0, I was "recxtiited" to work f~>r 
_ the "Guardian's Office" (G.O.) of the Church of Scientology.  
 I worked for Branch 1 of the Guardian's Office? which is  
/- 

\ .\ 

 concerned wit!: external inyclligence gathcririq. Anottier 
functio;? oi tl~c G.O. is tk,ot of an internal secret police. 
The primary contacts that I had in the G.O. were Chris 
Vetter, Bill Craig, and Michael Woods. 
 
 3) I]- - !_/ 198?, I was assigned to a project, the 
; : aose of which was for  me  to become a public opinion 
.: .Aer in the anti-cul t field and among those who were 
Lnvestigzting Scientology. This mission was assigned to me 
by 5il 1 Craig, and later confirmed by Michael Woods, both of 
whom were holding the position of Assistant Guardian for 
Information. Other G.n. officers confir-ed at various 
points in time the purpose of this mission. 
 
 4) The purpose of becoming a public opinion 
leader against the Church of Scientology was so that I could 
ini. trate and pentrate any individuals or groups opposed to   f e Church including Attorney Michael J. Flynn or Boston, 
Lassachasetts, who  
 .  
 .  

 I referred to in conversation with other 
.;' G.O. personnel as "The Flynn Network". However, specific 
limitations and delineations were at times,imposed by my 
.G.O. scneriors as regards to my activities involving Michael 
Flynn an? his associate attorneys in Boston.  

 -2-  

7 
5)  jn connectio:) with this project, I maintained 
 
my  position with the "Freedom Counseling Center" in Burlirlgame, 
California as a "counselol'" or "deproqrarnmer". I had previously secured this position in November 1980 as a consequence 
of another G.O. project. 

6)  A. 2’ deal of the information that X gathered 
.  
 .~ cerning anybody who criticized the Church of Scientology 
. ..ould pass on to the G.G. 

7!  In Jancary 1981, I contacted Attorney Michael 
Flynn for the purpose of becoming his client in order to 
bring a potential lawt.:it against the C?vzrch. This particular mission WL~ very closely monitored by the G.O. For 
this purpose, I used Henrietta Crampton of the Citizens' 
Freedom Foundation in Redondo Beach, California. She was 
well known in the anticult field and did not suspect that I 
was 3 Zcicntology agent. In my initial contact I informed 
-( A$torney Flynn of my cover story, whereupon he transferred 
 
 b  
 e to Kevin  Flynn,  who requested that myself and my wife 
/ write out a "statement" of our experiences within the Church 
 
O f  Scientology. After receiving clearance from the G.O., X 
sent an unsworn statement to Michael Flynn in February 1981. 
--that time, Bill Craig again informed me that the Flynn 
office had been penetrated and that the G.O. had secured  
 At  

7 

 extensive information abou: the "Flynn Network". 
Craig told me this time that the purpose of contacting 
Attorney' Flynn at that time was to obtain credentials as an 
anti-Scientologist crliich would be enhanced because of my 
ass.ociation with the "Flynn Network". These credentials 
cou~;j be used for other intelligence gathering or espionage 
Cd! 1rations. 

8)  Craig informed me on numerous occasions that 
the Flynn office had been penetrated and that it was in the 
process of "taking him down" t!li..agh lawsuits and disbarment  
 - . 
nroceec;ngs. 
 
 9) In May 1981, Craig informed me that he wanted 
me to attend a meeting, in the Flynn office which was taking 
place around May 10, 1981 among various la\.:yers throughout 
+'le conrtry who were involved 
L in Scientology litigation.  
 . This me-eting was taking place in Boston, Massachusetts, and 
 
 /i  
 C aig authorized the payment of G.O. or Church money to fly 
/.to Boston for the purpose of "penetrating" this meeting.  

 Craig told me that al2 expenses for the trip, including 
airfare, hotel bill, etc., would be covered by cash from the 
G.O. I then flew to Los Angeles where I met with Gary 
Lawrence, and Jeff Sherrel, both of whom were G.O. opera-  
. 

 -4-  

7 
 tives. Sherrel introduced himself as the person in char,:c 
 
 of U.S.G.O. Branch 1 activities for the Yortheast sector, 
which included Boston and New York. They both briefed mc on 
various Flynn activi+ies and this "briefing" indicated that 
they had an extensive knowledge of the operations of Attorl-x: 'I\-nn's office. The total expenses for this trip were 
r 
-. .~9.94 all c - :: was paid to me in cash by Sherrel or 
.-. .-g before and after the meeting in Pyston. 
 
10)  After this "briefing", I flew to Boston where 
I waited briefly in a room from which I coul;; overhear a few 
closin; comments by blichael Flynn in the meeting of attorneys 
and also me:: with "red .Trreph, an attorn-y from Washington, 
3.C. in regard to my own case. 'I reported the details of 
the meeting that I had obtained to the G.O. including how 
man\ I saw in attendance, the names of those I was introduced 
to, and suecificallv whatever I heard state3 to the best of 
 
mv  At no time during this meeting did I  
 - &ilit\. to recall. 
. Iever hear Michael Flynn mention Flynn Associates Management 
kompeq (FAMCO) or that FAMCO would in any way participate 
.'  
 in the fee relationship, no; did I repczt to the G-0. or 
 
make  any mention of FAMCO. 
 
 11) After the meeting, I was thoroughly debriefed 
by Jeff Sherre,   1 and Gary Lawrence and they informed me that  
. 

 -5-  

 "Flynn's dalvL; were numbe! cd" and that the)* were in the 
process of "taking him down". 
 
 12) :,. 1:: : used my contacts with Attorney Michael 
Flynn to further establish my credentials among anti-Scic.:Lologists, wherein using this cover I became involved in 
BrL;llerous operil,&orls into situations to which I would not 
:ve been privy without the Flynn cover. 

 
 ,'3) On one occasion, Bill Craig informed me that 
his supervisor, Peter Alvettt said that one of the means 
that the G.O. had used t;, penetrate the Flynn office was the 
placemen': of Silvana .ritano there as his secretary.  
 Craig informed me that after Garritano was placed as a G.O. 
agent, Chris Vetter related being present at a big party at 
the U.S.G.O. after the announcement to the other Lranches of 
the V.S.G.0. that Garritano was openly taking steps to get 
. Flynn disbarred with the claim that Garritano was used to  
 /  
 / Craig informed me that Flynn would be disbarred shortly with 
the Garritano operation. Several times I was informed by 
G.O. personnel that the Church of Scientology had received 
legal advice which was being followed by the Church of 
Scientology and tha,+ therfore the G.O. public relations  
. 

 sign a false affidavit under the duress of Michael Flynn.  

 /'  

 legal  

 -6-  

 bureau had ceased the publit* dissemination  Gi  information 
against thti impending disbarment of Flynn so that the Massachusetts Bar Association would not view it as a media 
campaign. 

 
14 ) 1 1. e P ‘- .- ” .-‘I 
 later t!lat one of the attorneys who 
:; I. resent at the May 1981 meeting was Greg Hull of San 
 
1 .’ .isco,  California. As a result of my connection with 
t..<: Flynn office I was able to penetrate ':ull concerning the 
number of potential litigants against the Church in the San 
Francisco area. On many occasions, I was requested by Bill 
Craig, operating he stat*? d on urgent requ(>.:ts and orders 
from the U.S.G.O. tc intimidate Hull and prevent him from 
bringing cases against the Church of Scientology by in part, 
informin? him of the impending Flynn disbarment using the 
claim that Silvana Garritano had been forced to sign a false 
a: fit' 7vit.  
?’ 

4 

/ 
/ 
 15) I was, at one point, informed that Xichael 
,F'lvnn was being followed, that he looked terrible, and that  
 .a 
the operations against hin: were extremely successful. 
 
 16) In connection with my nationally established 
position, I received weekly.calls from sources throughout  

 --. t I.A.  

 the United States, including Paulette Cooper, providing me 
with information of the activities of MiChdel Flynn and the 
cases he was invo'lved in against the Churc!l.  

. 
 17) Around November 1981, an individual named Joan 
_..  das  refel- r,lysc‘lf to Greg Hull for the purpose of 
>resenting Ms. Eden in a lawsuit against the Church for 
.>ud in connection with the Church's promise to cure her 
leukemia. Ms. Eden contacted the Freedom Counseling Center, 
though I refused to see her as a client. Clearly stating 
this fact to botli Lowell StreiJ.;r (the Executive Director of 
the FreedoT Counselin Center who Ms. 1' zn was seeing) and 
to Ms. Eden, I w&s  able  to debrief her on her legal situation. 
I learned that her previous attorney in Sacramento had 
discovered discredible information regarding Ms. Ec'en's past 
history and had been discouraged from pursuing her suit.  
 Ani-;che- member of the counseling center, Lowell Streiker,   Get with Ms. Eden and several members of the G.O. After 
/that mectlng, I met secretively with Woods and Jeff Shivelle, 
I 
the Congtroller's Assistant for Information who had been 
meetin:? that day with Lowell Streiker and Ms. Eden. I 
rein&Cormed Woods of the inside information previously 
gathered 
. --and reported to him. Eden had paid a considerable 
amount of money to t!lz Church including taking  out a  mortgage 

 -8-  
 .*  

 on her home in order to come up with money to pay for 
auditiny in order to curt her leukemia. Later, after the 
G.O. successfully prevented a settlement from going through, 
Eden died, and ;..c‘ 6.0. became extremely concerned that the 
Ci-:,rch of Scientology could be made subject to a successful 
k : i ',;~:ful death -,I; t . 
 
 19) In January 1992, I received a partial copy 
L&L the "Flynn Report" to the Clearwater City Commission 
about the Church of Scientclogy. In connection with this 
Report, and a biography of L. -)n Hubbard done by Michael 
iinn Shannon and ttle facts of a deprogr::nuning I was currently 
involved ill, I lr 3rneL Lnings about Scientology and L. Ron 
Hubbard which stunned me into a realization about what I was 
doing. I then went to Margaret Singer, a well known psychologist 
invclved in,cult cases and informed her of some of Lhe types 
 
O f  ti:incc that I had been doing. Subsequently, I went to 
. ;he _Teceral Bureau of Inves=igetion and to r-he Justice 
 
 /  
 Department concerning my activities. The G.O. was unaware 
I of the fact that I had gone in such a manner to Dr. Margaret  
 Singer, the Justice Department or the F.B.I. 
 
 19) In March 1982, Michael Woods and Peter Alvette 
were ordered to go to Boston, where I met with Woods. woods 
 
 -9-  

7 
 told  me  that the reason hz was in Boston was to get new 
agents into t!le Flynn office because the last mission 
seeking to penetrate the Flynn office had failed. He told 
 
me  that since thev had lost their last  agent  inside the 
Flynn office, the only line they had in on him  was  his 
c .  ‘-:.dc;;?.  He told me that although Flynn now had a shredder, 
: 5.0. was :-:' :.#le to piece the shredded pieces back  
 !ether, and that they had an individual who was  a  spe-.llict in connection with such operations. Woods told me 
&at he had a list of 160 people who were then being considered as new agents to penetrate the Flynn office. These 
agents were in t?le process of Icing recruited by the G.O. 
Woods regucsted that n+.il another agen could be successfully placed in t,,e Flynn office I re-establish my penetration. At that time, after several meetings with Woods, 
in which he pleaded and urged that I conduct the ty$e of 
penetration described, I agreed. Although I  was  secretly 
ou: of Scientology at that time, and had already gone to the 
8 F I,  

 1  
 I had previously discussed at length the reason why I 
couldn't penetrate the Flynn office further including the 
/  
 ' fact that Flynn would likely use me as a witness placing me 
in a position wherein to keep my cover I would have to 
perjure myself and which I had stated many times, I would 
not do. Woods told me that I should state various "half 
truths" without stating that I should directly perjure  

3s c,’ - 
 -lO- r:  
+ . 
 . u 4 9  

7 
 myself. At tne time, I was caught in between having gone to 
the FB1 without the G.O. knowing it, and still being considered an intern-1 double agent for the G.O. Woods requested 
that I call Attorney Thomas Hoffman from the Flynn office 
C* :lse my uneasiness regarding the credibility of L. Ron  
 . ..%rd. Jr. .I :+on for the discussion. I pretended 
rcme nervousness after being present at the Center on 
tructive Cultism in Weston, Mass. with a freshly deproqrarnmed Scientolouist while present at the same moment was a 
server attempting to serve Llr. : tack Clark wit!1 his second 
Scientology suit. I used r:L-rvocisness of my cover being 
blown as a device to b*---:- my return tc jari Francisco, 
wherein Woods calAed me repeatedly seeking to use me to 
prevent L. Ron Eubbard, Jr. from testifying in Clearwater.  
 I refused all of the operations that he wanted me t) participate in for the foregoing purpose. WoGds told me that 
the Gperntion to prevent L. Ron Hubbard, Jr. from testifying 
8  
 II'd become a top level G.O. order and that 1 was to use all 
P 
I of my credentials in connection with F1;rnn and with Hubbard, 
J r . in order to prevent Hubbard, Jr.'s testimony.  

 20) On April 13, 1982 an individual whose name  

-11- 

 was "Steve" came to meet me with Michael Woods and informed 
me that he, Steve, was i;, charge of a mission called "All 
Clear" in orcjer to get Hubbard's name off all of the litigation against .::,urch of Scientology. They further informed me that an individual named Gerry Armstrong had rec , ._. 
 * !y defected and that Armstrong had 
.‘A:- Garrison ca.': :::I.-ning a forthcoming 
.rd. They informed me 'Aat Armstrong  
 been working with 
biography about Hubhad defected and that 
I-mstrong had had access to L. Ron Hubbard, Jr.'s B-l file, 
which contained correspondence between myself and Hubbard, 
Jr. They told me that Armst~ ; had been in touch with L. 
Ron Hubbard, Jr. since his defection and they feared he 
might be .-:Jle to ded, - was-a double agent for the G.O. 
Steve ordered me to disseminate information that Armstrong 
was actually a G.O. agent and was not to be believed by 
opponents of Scientology. I advised him tnat this wtiuld be 
stupid and that Paulette Cooper would love to subpoena Gerry 
- Armstrong. Steve then recinded the order.  
 I 

,,/ 
I 21’ ,  Subsequently, I contacted Paulette Cooper, who 
was involved in lit'gat:on against the Church of Scientology, 
and Michael _Flynn and informed them that from November of 
1980 until January of 1982 I had been operating as a double 
agent for the Church of Scientology. Mr. Flynn requested me  
 1980  

 -12-  

7 
 to prepare a statement relative to my activities. Although 
the operations I have been involved in cover hundreds of 
situations in which I acted as an espionage agent for the 
G.O. passing on _.. sT;,,tation to them and doing what they 
ret-11 sted me to do, this affidavit is merely intended to be 
CT L.. .  .;,?s-iil  outline of operations 1 was involved in against 
_' ,.a<~ Flynn. 
 
 Signed under the pains and penalties of perjury 
L3 +A 
this , - , 1982.  
.