Gerry Armstrong--Scientology's Response to Request for Production of Documents

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[CT 6288]

JOHN G. PETERSON
PETERSON AND BRYAN
8530 Wilshire Boulevard, Suite 407
Beverly Hills, California 90211
(213) 659-9965

Attorneys for Plaintiff and Cross-Defendant
CHURCH OF SCIENTOLOGY OF CALIFORNIA

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

CHURCH OF SCIENTOLOGY OF
CALIFORNIA, a California
Corporation,

Plaintiff,

GERALD ARMSTRONG, et al.,

Defendants.

AND RELATED CROSS-ACTION.

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CASE NO. C 420 153

CROSS-DEFENDANT CHURCH OF
SCIENTOLOGY OF CALIFORNIA'S
RESPONSE TO CROSS-COMPLAINANT
GERALD ARMSTRONG'S REQUEST
FOR PRODUCTION OF DOCUMENTS

Cross-Defendant Church of Scientology of California

responds to Cross-Complainant's Request for Production of

Documents as follows:

1. without waiving any objections, Cross-Defendant

responds that, to the extent said documents pertaining to

Cross-Complainant exist, they have already been produced.

2. Cross-Defendant will produce the documents in its

possession, custody or control.

3. Cross-Defendant has no such documents in its

possession, custody or control.

4. Without waiving any objections, Cross-Defendant

[CT 6289]

responds that it has no such documents in its possession,

custody or control.

5. Without waiving any objections, Cross-Defendant

responds that to the extent that any documents exist within

this category, said documents have already been produced.

6. Cross-Defendant has no such documents in its

possession, custody or control.

7. Without waiving any objections, Cross-Defendant

responds that to the extent that any documents exist within

this category, said documents have already been produced.

8. Cross-Defendant has no documents which show any

alleged assault of Cross-Complainant, running into him, or any

attempts to involve Cross-Complainant and Joyce Armstrong in

freeway accidents or any type of harassment. Correspondence

and reports to and from private investigators are privileged

as attorney work product.

9. Cross-Defendant has no such documents in its

possession, custody or control.

10. Cross-Defendant has no such documents in its

possession, custody or control.

11. Cross-Defendant denies that Cross-Complainant was

harassed in London in June 1984. Cross-Defendant is aware that

Cross-Complainant was legitimately served with a valid order

by the California Court of Appeal, and will produce documents

in our possession, custody or control.

12. Cross-Defendant has no such documents in its

possession, custody or control.

13. Without waiving any objections, no such orders,

[CT 6290]

reports or correspondence exist regarding Cross-Complainant.

As to documents, any that fall within this Request for

Production which pertain to Cross-Complainant either have

already been produced or are equally available to

Cross-Complainant.

14. Cross-Defendant is searching its files and will

produce any of the requested documents in its possession,

custody or control.

15. Cross-Defendant has no knowledge of any burglary of

Cross-Complainant's trunk. Hence, Cross-Defendant has no such

documents in its possession, custody or control.

16. Cross-Defendant has no such documents in its

possession, custody or control.

17. Cross-Defendant has no such documents in its

possession, custody or control.

18. Without waiving any objections, Cross-Defendant

denies that it has ever obtained any "false authorizations"

with respect to any alleged wiretapping of either Cross-

Complainant or Michael Flynn. No documents exist.

19. Cross-Defendant has no such documents in its

possession, custody or control.

20. Cross-Defendant has no such documents in its

possession, custody or control.

21. "Armstrong Operation" is a characterization invented

by Cross-Complainant as no such "operation" has ever existed.

Cross-Defendant has no such documents in its possession,

custody or control.

22. Cross-Defendant has no such documents in its

[CT 6291]

possession, custody or control. There is no such thing as an

operation to frame Flynn and Armstrong regarding the

$2,000,000 check. Object to production of documents regarding

check as not leading to discovery of admissible evidence

relevant to this case.

23. Cross-Defendant objects on the grounds that this

Request is vague, ambiguous, overbroad, burdensome and

harassive. The documents requested herein are irrelevant to

any cause of action in the cross-complaint and are not

calculated to lead to the discovery of any evidence admissible

in this action.

24. Cross-Defendant incorporates by reference as if fully

set forth herein its response to Request for Production No. 23.

25. This Request for Production seeks documents which,

in part, are irrelevant to any cause of action in the

cross-complaint and are not calculated to lead to the discovery

of any evidence admissible in this action. Any documents

which are calculated to lead to the discovery of admissible

evidence and which do exist have already been produced to

Cross-Complainant.

26. See response to Request #25.

27. Any such documents which exist have already been

produced to Cross-Complainant.

28. Any such documents which exist have already been

produced to Cross-Complainant.

29. Cross-Defendant has no such correspondence, orders,

reports, statements, payments, reports or cancelled checks in

its possession, custody or control. Cross-Defendant possesses

[CT 6292]

a declaration of L. Pletcher Prouty which will be produced.

30. Cross-Defendant will produce the requested videotape

in its possession, custody or control.

31. Cross-Defendant is informed and believes that

Cross-Complainant already has complete copies of the

videotapes requested herein. No other documents exist.

Nothing, either audio or visual, was edited from said

videotapes. There are no correspondence, orders, reports,

statements, documents or materials relating to an editing

prior to Christofferson.

32. Cross-Defendant has no such documents in its

possession, custody or control.

33. Cross-Defendant cannot locate any specific items

that have been sent to the media, however, a continued search

is being made to ascertain if items sent to media on other

subjects contained information regarding Cross-Complainant.

Cross-Defendant will supplement this response if any are

located.

34. Cross-Defendant has no such documents in its

possession, custody or control.

35. Cross-Defendant has no such documents in its

possession, custody or control.

36. Cross-Defendant has no such documents in its

possession, custody or control.

37. Cross-Defendant will produce all documents and

materials in our possession except memo to files dated

10-21-85, 11-19-85 and 11-20-85, from attorney Roger Geller

which is privileged as attorney work product.

[CT 6293]

Cross-Defendant has no such documents in its possession,

custody or control.

39. This Request for Production seeks documents which

are irrelevant to any cause of action in the cross-complaint

and is not calculated to lead to the discovery of any evidence

admissible in this action.

40. Cross-Defendant has no such documents in its

possession, custody or control.

41. Without waiving any objections, Cross-Defendant

denies that any "operation or mission" to "'Black PR"

Cross-Complainant" ever existed. Cross-Defendant has no such

documents in its possession, custody or control.

42. Cross-Defendant has no such documents in its

possession, custody or control.

43. Cross-Defendant has no such documents in its

possession, custody or control.

DATED: September 2, 1986

PETERSON & BRYNAN

BY: [signed]
JOHN G. PETERSON

See also Armstrong Declaration 10-11-1986

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