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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

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I, LAURIE J. BARTILSON, hereby declare:

1. I am a partner in the law firm of Bowles & Moxon and am

an attorney admitted to practice in the State of California. My

firm represents plaintiff Church of Scientology International

("Church") in the instant case. I am submitting this declaration

in support of the Church's Second Ex Parte Application for Order

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to Show Cause Why Gerald Armstrong Should Not Be Held in Contempt

("Application"). I have personal knowledge of the matters

specified in this declaration and, if called upon to testify on

such matters, would and could do so competently.

2. In the Church's December 31, 1992 ex parte application

for order to show cause in this case and in my supporting

declaration to that application and accompanying exhibits, the

Church documented at least six earlier instances of Armstrong's

wilful violations of the May 28, 1992 preliminary injunction

order of this Court ("May 28 order"). As required, my December

31, 1992 declaration ("First Dec.") contained allegations of: (a)

the issuance of the May 28 order ( First Dec., ¶ 2): (b) notice to

Armstrong of the May 28 order through notice to his attorneys on

June 5, 1992 in the manner authorized by the Court (First Dec., ¶

3): (c) Armstrong's knowledge of the May 28 order through his

statements that he was aware of but would never comply with such

order (First Dec., ¶¶ 4, 5, 9, 10 and 13); and (d) Armstrong's

ability to have complied with such order (through his actions of

assistance to anti-Church litigants, including his latest

instance specified in paragraph 5 below, Armstrong was just as

able to desist from such actions ( First Dec., ¶¶ 4, 5, 9, 11, 12

and 13)). My December 31, 1992 declaration is attached as

Exhibit 1 hereto and its statements and allegations are

incorporated by reference into this declaration.

3. The May 28 order states, in part:

Defendant Gerald Armstrong ... and persons acting in
concert ... with him ... are restrained and enjoined
during the pendency of this suit pending further order
of this court from ... [v]oluntarily assisting any
person ... litigating a claim against the persons

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referred to in sec. 1 of the " Mutual Release of All

Claims and Settlement Agreement " of December 1986.

Exhibit A to Application, May 28 order, p. 2, ¶ 6. The persons

and entities protected by the prohibition against voluntary

assistance include plaintiff Church and the Church of Scientology

of California. Exhibit B to Application, Mutual Release of All

Claims and Settlement Agreement, p. 1, ¶ 1.

4. Less than a month after the May 28 order was issued,

Armstrong asserted under oath in deposition that he would not

honor its terms.

I have absolutely no intention of honoring that
settlement agreement. I cannot. I cannot logically.
I cannot ethically. I cannot morally. I cannot
psychically. I cannot philosophically. I cannot
spiritually. I cannot in any way. And it is firmly my
intention not to honor it.

Q. No matter what the court says?

A. No court can order it. They're going to have to
kill me.

Exhibit C to Application, June 24, 1992 deposition of Gerald

Armstrong, p. 124. Armstrong also stated his intent to ignore

the May 28 order in a December 22, 1992 letter to plaintiff's

counsel. Exhibit D to Application.

5. Larry Wollersheim is a former Church member who has been

actively pursuing claims against the Church of Scientology of

California in litigation since 1980. On or about June 17, 1993,

I received a set of exhibits in support of Larry Wollersheim's

motion to strike in Church of Scientology of California v.

Wollersheim, Los Angeles County Superior Court No. 074815. I

represent the Church of Scientology of California in that case.

Designated as exhibit 6 in that set was a copy of a five-page

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declaration of Gerald Armstrong, showing on the last page that

Armstrong had executed the document under oath on June 4, 1993.

That declaration contained an Armstrong diatribe against the

Churches of Scientology. Exhibit J to Application.

6. I allege that execution and delivery of the June 4, 1993

declaration by Armstrong to Wollersheim and/or Wollersheim's

counsel is a violation of the prohibition in the May 28 order

against voluntary assistance to Church adversaries in litigation

and is in deliberate contempt of this Court's authority.

7. On July 23, 1993, I gave notice of this application to

Armstrong's counsel, Ford Greene and Paul Morantz, by telefax

communication. A true and correct copy of my letter giving

notice is attached hereto as Exhibit 2, together with telefax

transmission confirmation sheets. I received a response to my

letter from defendant Armstrong, Exhibit 3, and responded to that

communication on July 23, 1993, Exhibit 4.

Neither Armstrong nor his counsel indicated whether or not

they intended to oppose this application.

I declare under penalty of perjury under the laws of the

State of California that the foregoing is true and correct.

Executed on this 24th day of July, 1993 at Los Angeles,

California.

H:\ARMSTRON\LAURIE.DEC

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