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SETTLEMENT AGREEMENT

A. PRIOR SETTLEMENTS:

     Settlement agreements made prior to November 1,

1986 and prior to the collective settlement [HW] as stated below:

Client

 

Amount

 

Fee and Expenses

 

(1) Bears
$115,000.00
 To be determined
with local counsel
(2) Garritys
$175,000.00
 To be determined
with local counsel
(3) Petersons
$175,000.00
 To be determined
with local counsel
(4) Jefferson
$150,000.00
 To be determined
with local counsel
(5) Lockwood
$150,000.00
 To be determined
with local counsel
(6) Hartwell
$150,000.00

_______________
 To be determined
with local counsel
_______________
 
$915,000.00
 To be determined
with local counsel

B. INDEPENDENT SETTLEMENT:

     The Christofferson-Titchborne settlement was made

separate from the collective settlement. It was agreed to

between attorney Gary McMurray, his client, Julie

Christofferson-Titchborne and the Church of Scientology.

-1-

 

Client

 

Amount

 

Fee and Expenses

 

Christofferson-
Titchborne
$100,000.00

To be determined
by attorney
McMurray and
client. None of
the attorneys
representing other
clients in the
collective settle-
ment represent or
have represented
Christofferson-
Titchborne.

C. COLLECTIVE SETTLEMENT:

     The following cases/clients are part of a collec-

tive settlement made on December     11    , 1986. The undersigned

acknowledge that the settlement set forth above in Para-

graphs A and B were made as separate settlements, meaning

that the cases/clients listed in Paragraphs A and B agreed

to the amounts stated therein prior to the collective

settlement as in Paragraph A, and independent from the

collective settlement as in Paragraph B. The total amount

of the collective settlement is $2,800,000.00. The total

amount of the collective settlement and the prior inde-

pendent settlements in Paragraphs A and B is $3,815,000.00.

The collective settlement allocation is as follows:

Client

 

Amount

 

Fee and Expenses

 

(1) Nancy Dincalci
$     7,500.00

None
(2) Kima Douglas
$     7,500.00
None
[HW][Michael Douglas] 
[HW][$7,500.00]
 [None]

-2-

 

(3) Robert Dardano
$    15,000.00

None
(4) Warren Friske
$    15,000.00
None
(5) William Franks
$    40,000.00
None
(6) Laurel Sullivan
$    40,000.00
None
(7) Edward Walters
$   100,000.00
To be determined
between client and
attorneys
(8) Howard Schomer
$   200,000.00
To be determined
between attorney
Bunch and client
(9) Martin Samuels
$   500,000.00
To be determined
between attorney
McMurray and
client
(10) Gerald Armstrong
v. Church of
Scientology
$   800,000.00
To be determined
between attorney
Bunch and client
(11) Fees and expenses
to attorneys
Contos & Bunch,
Robert Kilbourne,
Michael Flynn, and
associated counsel
for the prosecution
and defense of various
cases including the
"Hubbard documents"
case, the "check-
frame up" case and
the defense of
approximately 17
lawsuits against
attorney Flynn and
his clients.
$   500,000.00
To be determined
between attorneys
Contos & Bunch,
Michael Flynn,
Robert Kilbourne,
and associated
counsel

(12) Flynn v. Ingram
(No. __________ )
Flynn v. Hubbard
(No. __________ )

$   575,000.00

-0-
_______________

To be determined
between attorney
Flynn and his
counsel          
 
$ 2,800,000.00
 

 

-3-

 

     We, the undersigned, agree and acknowledge that

(1) we have read the foregoing Settlement Agreement;

(2) that we agree with the total settlement amount and the

allocations to the respective cases/clients as set forth

therein; (3) that we have either consulted, been advised to

consult or have had the opportunity to consult with

attorneys other than Michael J. Flynn who, we acknowledge is

also a claimant against the Church of Scientology and L. Ron

Hubbard; (4) that we agree to maintain the confidentiality

of this Settlement Agreement; (5) that we acknowledge that

many of the cases/clients involved in this settlement have

been in litigation against the Church of Scientology for

more than six to seven years, that many have been subjected

to intense, and prolonged harassment by the Church of

Scientology throughout the litigation, and that the value of

the respective claims stated therein is measured in part by

the (a) length and degree of harassment; (b) length and

degree of involvement in the litigation; (c) the individual

nature of each respective claim in connection with either

their involvement with the Church of Scientology as a member

and/or as a litigant; (d) the unique value of each

case/client based on a variety of things including, but not

limited to, the current procedural posture of a case,

specific facts unique to each case, and financial, emotional

or consequential damage in each case; that we agree and

-4-

 

acknowledge that Michael J. Flynn has primarily been

responsible for bearing the cost of the litigation over a

period of approximately seven years, that he or his firm's

members have been required to defend approximately 17

lawsuits and/or civil/criminal contempt actions instituted

by the Church of Scientology against him, his associates and

clients, that he and his family have been subjected to

intense and prolonged harassment, and that his claims

against the Church of Scientology and L. Ron Hubbard, and

his participation as an attorney have a unique value which

is accurately and properly reflected in the allocations set

forth herein.

[signed] NANCY DINCALCI
NANCY DINCALCI 		DATE: Dec 5, 1986
[signed] KIMA DOUGLAS
KIMA DOUGLAS		 DATE: Dec 5 - 1986
[signed] ROBERT DARDANO
ROBERT DARDANO		 DATE: Dec-20-1986
______________________________
WARREN FRISKE		 DATE: __________
[signed] LAUREL SULLIVAN
LAUREL SULLIVAN		 DATE: Dec  , 1986
[signed] MICHAEL DOUGLAS
[HW] MICHAEL DOUGLAS		 DATE: Dec 5, 1986
[signed] Julie Christofferson Titchbourne
[HW] Julie Christofferson Titchbourne		 DATE: Dec 6, 1986

-5-

 

[HW]______________________________
CAROL GARRITY		 DATE: ____________________
[HW]______________________________
Paul Garrity		 DATE: ____________________
[signed] WILLIAM FRANKS
WILLIAM FRANKS		 DATE:  [ illegible ]
[signed] EDWARD WALTERS
EDWARD WALTERS		 DATE:  December 7th, 1986
[signed] HOWARD SCHOMER
HOWARD SCHOMER		 DATE:  12-5-86
[signed] MARTIN SAMUELS
MARTIN SAMUELS		 DATE: Dec. 4, 1986
[signed] G. ARMSTRONG
GERALD ARMSTRONG		 DATE: 12-6-86

______________________________
MICHAEL J. FLYNN

 

DATE: ____________________

 

CONTOS & BUNCH
A PROFESSIONAL CORPORATION

 

  
By:[signed] JULIA DRAGOJEVIC
BRUCE M. BUNCH
[HW] JULIA DRAGOJEVIC		 DATE:  12-10-86
[signed] GARRY P. MC MURRY
GARY MC MURRAY		 DATE: December 6, 1986
______________________________
ROBERT KILBOURNE		 DATE: ____________________
______________________________
[HW] JANE Peterson		 DATE: ____________________
______________________________
[HW] Richard Peterson 		DATE: ____________________
[signed][ illegible ]
[HW] illegible		 DATE: [illegible]

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