§   What's New   ||  Search   ||  Legal Archive  ||  Wog Media  ||  Cult Media  ||  CoW ® ||  Writings  ||  Fun  ||  Disclaimer  ||  Contact  §

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3071]

Andrew H. Wilson
WILSON, RYAN & CAMPILONGO
235 Montgomery Street
Suite 450
San Francisco, California 94104
(415) 391-3900

Laurie J. Bartilson
BOWLES & MOXON
6255 Sunset Boulevard, Suite 2000
Hollywood, CA 90028
(213) 953-3360

Attorneys for Plaintiff
CHURCH OF SCIENTOLOGY
INTERNATIONAL

[stamp]
FILED

JUL 23 1993

HOWARD HANSON
MARIN COUNTY CLERK
BY: C. HARDING DEPUTY
[signed] C Harding

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF MARIN

CHURCH OF SCIENTOLOGY
INTERNATIONAL, a California not-
for-profit religious corporation,

Plaintiff,

vs.

GERALD ARMSTRONG; MICHAEL WALTON;
THE GERALD ARMSTRONG CORPORATION,
a California for-profit
corporation; DOES 1 through 100,
inclusive,

Defendants.


)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

CASE NO. 157680

VERIFIED COMPLAINT TO SET
ASIDE FRAUDULENT TRANSFERS
AND FOR DAMAGES; CONSPIRACY

[C.C. §§ 3302,
3439. 07 (a) (1) , (3)
DATE:
TIME:
DEPT:

DISCOVERY CUT-OFF: None
MOTION CUT-OFF: None
TRIAL DATE: None

Plaintiff, by its attorneys, Wilson, Ryan & Campilongo and

Bowles & Moxon, for its Complaint, alleges:

NATURE OF THE ACTION

1. In December, 1986, plaintiff and defendant Gerald

Armstrong ("Armstrong") entered into a settlement agreement ("the

Agreement"). The Agreement provided for a mutual release and

 

1

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3072]

waiver of all claims arising out of a cross-complaint which

defendant Armstrong had filed in the case of Church of

Scientology of California v. Gerald Armstrong, Los Angeles

Superior Court No. C 420153. Armstrong, a former Church member

who sought, by both litigation and covert means, to disrupt the

activities of his former faith, displayed through the years an

intense and abiding hatred for the Church, and an eagerness to

annoy and harass his former co-religionists by spreading enmity

and hatred among members and former members. Plaintiff sought,

with the Agreement, to end all of Armstrong's covert activities

against it, along with the litigation itself. For that reason,

the Agreement contained carefully negotiated and agreed-upon

confidentiality provisions and provisions prohibiting Armstrong

from fomenting litigation against plaintiff by third parties.

These provisions were bargained for by plaintiff to put an end to

the enmity and strife generated by Mr. Armstrong once and for

all. The Agreement also provided, inter alia, for liquidated

damages to be paid by Armstrong should he choose to breach these

provisions.

2. In or about February, 1990, Armstrong began to take a

series of actions which directly violated provisions of the

Agreement. Fearing that plaintiff would seek to collect the

liquidated damages owed by his breaches, Armstrong, as set forth

below, fraudulently conveyed all of his property, including real

property located in Marin County, cash, and personal property to

defendants Michael Walton, the Gerald Armstrong Corporation, and

Does 1-100, receiving no consideration in return. Thereafter,

Armstrong deliberately set out to repeatedly breach the

 

2

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3073]

Agreement, incurring a debt which at present totals at least

$1,800,000, and which he has and had no assets to use to satisfy

the debt.

3. Armstrong's breaches and resulting indebtedness are

presently the subject of two actions pending in Los Angeles

Superior Court, Church of Scientology International v. Armstrong,

LASC No. BC 052395 ("the First Action"), demanding liquidated

damages of $600,000.00 for breaches occurring between July, 1991

and May, 1992, and Church of Scientology International v.

Armstrong, LASC No. BC 084642 ("the Second Action"), demanding

liquidated damages of $1,200,000.00, for breaches occurring

between August, 1991 and June, 1993.

THE PARTIES

4. Plaintiff Church of Scientology International is a non-

profit religious corporation incorporated under the laws of the

State of California, having its principal offices in Los Angeles,

California. Plaintiff CSI is the Mother Church of the

Scientology religion.

5. Defendant Gerald Armstrong is a resident of Marin

County, California.

6. Defendant Michael Walton is a resident of Marin County,

California.

7. Defendant Gerald Armstrong Corporation ("GAC") is a

corporation incorporated under the laws of the State of Calif-

ornia, having its principal offices in San Anselmo, California.

8. Plaintiff is ignorant of the names and capacities of

the defendants identified as DOES 1 through 25, inclusive, and

thus brings suit against those defendants by their true names

 

3

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3074]

upon the ascertainment of their true names and capacities, and

their responsibility for the conduct alleged herein.

DEFENDANT GAC IS THE ALTER EGO OF

DEFENDANT ARMSTRONG

9. Defendant Armstrong is GAC's president and sole

officer, its principal shareholder and sole employee, and has

been since the incorporation of GAC in 1987. Further, defendant

Armstrong has the sole and exclusive right to control the

corporation's bank account and its disbursement of funds.

10. Defendant GAC is, and at all times since its

incorporation was, the alter ego of defendant Armstrong. There

exists, and at all times since GAC's incorporation has existed, a

unity of interest and ownership between these two defendants such

that any separateness between them has ceased to exist:

Defendant Armstrong caused his own personal assets to be

transferred to GAC without adequate consideration in order to

evade payment of his lawful obligations, and defendant Armstrong

has completely controlled, dominated, managed and operated GAC

since its incorporation for his own personal benefit.

11. Defendant GAC is, and at all times mentioned was, a

mere shell, instrumentality and conduit through which defendant

Armstrong carried on his activities in the corporate name exactly

as he conducted them previous to GAC's incorporation. Armstrong

exercised and exercises such complete control and dominance of

such activities that any individuality or separateness of

defendant GAC and defendant Armstrong does not, and at all

relevant times did not, exist.

12. Adherence to the fiction of the separate existence of

 

4

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3075]

defendant GAC as an entity distinct from defendant Armstrong

would permit an abuse of the corporate privilege and would

sanction fraud, in that Armstrong transferred his material assets

to GAC in 1988, at the time of his embarkation on the campaign of

harassment described herein, and with the intention of preventing

plaintiff from obtaining monetary relief from Armstrong pursuant

to the liquidated damages clause. Hence, GAC exists solely so

that Armstrong may be "judgment proof."

THE CONTRACT

13. On or about December 6, 1986, CSI and Armstrong entered

into a written confidential settlement Agreement, a true and

correct copy of which is attached hereto as Exhibit [A], and

incorporated by reference.

14. The Agreement was entered into by plaintiff and

defendant Armstrong, with the participation of their respective

counsel after full negotiation. Each provision of the Agreement

was carefully framed by the parties and their counsel to

accurately reflect the agreement of the parties.

15. Plaintiff specifically negotiated for and obtained from

Armstrong the provisions in the Agreement delineated in

paragraphs 7(D), 7(H), 7(G), 10 and paragraphs 12 through 18.

Plaintiff took this step because it was well aware, through

investigation, that Armstrong had undertaken a series of covert

activities, apart from the litigation, which were intended by

Armstrong to discredit Church leaders, spark government raids

into the Churches, create phony "evidence" of wrongdoing against

the Churches, and, ultimately, destroy the Churches and their

leadership.

 

5

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3076]

16. Paragraph 7(D) of the Agreement provided, in substance,

that Armstrong: (1) would not create or publish, or assist

another in creating or publishing, any media publication or

broadcast, concerning information about plaintiff, L. Ron Hubbard

or any other persons or entities released by the Agreement; (2)

would maintain "strict confidentiality and silence" with respect

to his alleged experiences with plaintiff or any knowledge he

might have concerning plaintiff, L. Ron Hubbard, or other

Scientology-related entities and individuals; (3) would not

disclose any documents which related to plaintiff or other

identified entities and individuals; and (4) would pay to

plaintiff $50,000 in liquidated damages for each disclosure or

other breach of that paragraph.

17. Contemporaneously with the signing of the Agreement,

Armstrong represented that he understood the Agreement's

provisions and was acting of his own free will and not under

duress.

18. The Agreement also provided that plaintiff CSI would

pay to Armstrong's attorney, Michael Flynn, a lump sum amount

intended to settle not just Armstrong's case, but the cases of

other clients of Mr. Flynn as well, and that Mr. Flynn would pay

to Armstrong a portion of that settlement amount. The exact

amount of the portion to be paid to Armstrong by Mr. Flynn was

maintained as confidential between Mr. Flynn and Armstrong.

19. CSI paid to Mr. Flynn the lump sum settlement amount.

20. Mr. Flynn paid to Armstrong his confidential portion of

the lump sum settlement amount, which was at least $520,000,

after expenses.

 

6

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3077]

21. The consideration paid to Armstrong was fair,

reasonable and adequate. Plaintiff CSI has performed all of its

obligations pursuant to the Agreement.

BREACHES OF THE AGREEMENT

22. Beginning in February, 1990, and continuing unabated

until the present, Armstrong has breached the Agreement wilfully

and repeatedly, including, inter alia, the provisions of

Paragraph 7(D) of the Agreement which require Armstrong to pay

plaintiff liquidated damages for each such breach.

23. In addition to the breaches of the Agreement which

invoke the liquidated damages clause, Armstrong has committed

additional violations of provisions of the Agreement which

entitle plaintiff to compensatory damages according to proof.

24. Despite demand by plaintiff, Armstrong has refused to

pay any damages, liquidated or compensatory, for the deliberate

breaches of the Agreement described herein.

25. The breaches described herein are presently the subject

of litigation in the First Action and the Second Action, and have

not yet been reduced to judgment.

FIRST CAUSE OF ACTION

TO SET ASIDE FRAUDULENT TRANSFER OF REAL PROPERTY

(Against Defendants Gerald Armstrong and Michael Walton)

26. Plaintiff realleges paragraphs 1 - 25, inclusive, and

incorporates them herein by reference.

27. On or about August 24, 1990, defendant Gerald Armstrong

was an owner and in possession and control of that real property

situated in Marin County known as 707 Fawn Drive, San Anselmo,

California, and more particularly described as follows:

 

7

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3078]

PARCEL ONE

PARCEL TWO as shown upon that certain Parcel Map
entitled, "Parcel Map Lands of California Land Title
Portion Lands described in book 2887 of Official
Records, at page 367, also being Portion of Lots 501
and 501-A unrecorded Map of Sleepy Hollow Acres,
Vicinity of San Anselmo, Marin County, California,
filed for record April 8, 1976 in Volume 12 of Parcel
Maps, at page 43, Marin County Records.

EXCEPTING THEREFROM that portion deeded to Alain Pigois
and Nina Pigois, husband and wife, as community
property, by Deed recorded February 27, 1989, Serial
No. 89 13373.

PARCEL TWO

AN EASEMENT for ingress, egress and public utility
purposes described as follows:

BEGINNING at a point on the centerline of Fawn Drive,
said point being the most southwesterly corner of
Parcel 3, as shown upon that certain map entitled,
"Parcel Map Lands of California Land Title Portion
Lands described in Book 2887 of Official Records, at
page 367, also being a portion of Lots 501 and 501-A,
unrecorded Map of Sleepy Hollow Acres, Vicinity of San
Anselmo, Marin County, California", filed for record
April 9, 1976 in Volume 12 of Parcel Maps, at page 43,
Marin County Records, said point also being the
intersection of the calls "South 26° 20' East 135 feet
and North 63° 401 East 20 feet" as contained in Parcel
2 of the Deed executed by California Land Title
Company, a corporation to Michael C. McGuckin, et ux,
recorded March 26, 1976 in Book 3010 of Official
Records, at page 190, Marin County Records; thence from
said point of beginning and along the exterior boundary
of said Parcel 3, North 63° 40' East 20 feet; thence
North 75° 07' 20" East 164.00 feet; thence leaving said
exterior boundary of Parcel 3, North 12° 411 East 85.00
feet; thence North 30° 45' West 126.00 feet, thence
North 13° 30' East 79.21 feet to the northwesterly
boundary of Parcel 1, as shown upon that certain map
referred to hereinabove; thence along the exterior
boundary of said Parcel 1, South 84° 00' west 75.70
feet to the most Northerly corner of the parcel of land
described in the Deed executed by Charles B. Roertson,
et ux, to Paul Hopkins Talbot, Jr., et ux, recorded
January 30, 1956 in book 1002 of official Records, at
page 623, Marin County Records; thence 111.77 feet,
thence leaving said exterior boundary of Parcel 1,
South 18° 45' East 95.06 feet thence South 21° 48' West
70.66 feet; thence South 75° 07' 20" West 160.00 feet
to the certline of Fawn Drive; thence along the

 

8

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3079]

exterior boundary of said Parcel 3, also being the
centerline of "Fawn Drive, South 26° 20' East 34.46
feet to the point of beginning.

28. On or about August 24, 1990, defendants

Gerald Armstrong and Michael Walton transferred by grant deed the above-

described property to defendant Michael Walton. On August 27,

1990, the grant deed was recorded in Marin County Official

Records as number 90 50497 in the Office of the County Recorder

of Marin County, California.

29. Plaintiff is further informed and believes and thereon

alleges that the transfer was made with an actual intent to

hinder, delay or defraud plaintiff in the collection of its

damages.

30. Further, plaintiff is informed, and believes, and

thereon alleges that at the time Armstrong made the transfers, he

intended in the future to engage in the conduct in breach of his

Agreement with plaintiff, described above, knowing that he would

thereby incur the damages described herein and for which he would

have rendered himself judgment-proof.

31. Defendant Armstrong received no money or other

consideration in exchange for the aforementioned transfer.

Plaintiff is informed and believes and thereon alleges that at

the time of the transfer of the real property defendant

Armstrong's interest in the real property was not less than

$397,500.00. Thus, defendant Armstrong did not receive

reasonably equivalent value in exchange for his interest in the

real property.

32. Plaintiff is informed and believes and thereon alleges

that defendant Walton received the above-described real property

 

9

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3080]

with knowledge that defendant Armstrong intended to (1) hinder,

delay or defraud the collection of plaintiff's aforementioned

damages and (2) further breach his Agreement with plaintiff,

thereby incurring substantial damages which it would be

impossible for Armstrong to pay. Defendant Walton had previously

advised Armstrong concerning the Agreement and was familiar with

its terms and conditions; further, Armstrong had informed

defendant Walton of his vendetta against plaintiff and all

Churches of Scientology, and of his intentions to breach the

Agreement. Moreover, Walton was well aware of the fraudulent

nature of the transfer, for which he received no money or other

consideration.

SECOND CAUSE OF ACTION

TO SET ASIDE FRAUDULENT TRANSFER OF ASSETS

(Against All Defendants)

33. Plaintiff realleges paragraphs 1-25, inclusive, and

incorporates them herein by reference.

34. On or about August, 1990, defendant Gerald Armstrong

was the owner and in possession and control of approximately

$41,500 in cash, and shares of stock in The Gerald Armstrong

Corporation which were valued by Armstrong at $1,000,000.

35. On or about August, 1990, Armstrong transferred the

$41,500 in cash and the shares of stock in The Gerald Armstrong

Corporation to defendants Walton and Does 1 - 100.

36. Plaintiff is further informed and believes and thereon

alleges that the transfer was made with an actual intent to

hinder, delay or defraud plaintiff in the collection of its

damages.

 

10

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3081]

37. Further, plaintiff is informed, and believes and

thereon alleges that at the time Armstrong made the transfers, he

intended in the future to engage in the conduct in breach of his

Agreement with plaintiff, described above, knowing that he would

thereby incur the damages described herein, and for which he

would have rendered himself and his corporation judgment-proof.

38. Defendant Armstrong received no money or other

consideration in exchange for the aforementioned transfer.

Plaintiff is informed and believes and thereon alleges that at

the time of the transfer of the cash and stock, defendant

Armstrong's interest in the cash and stock was not less than

$1,041,500. Thus, defendant Armstrong did not receive reasonably

equivalent value in exchange for his interest in the transferred

assets.

39. Plaintiff is informed and believes and thereon alleges

that defendants Walton and Does 1 -100 received the above-

described real property with knowledge that defendant Armstrong

intended to (1) hinder, delay or defraud the collection of

plaintiff's aforementioned damages; and (2) further breach his

Agreement with plaintiff, thereby incurring substantial damages

which it would be impossible for Armstrong or his corporation to

pay. Defendant Walton had previously advised Armstrong

concerning the Agreement and was familiar with its terms and

conditions; further, Armstrong had informed defendant Walton and

Does 1-100 of his vendetta against plaintiff and all Churches of

Scientology, and of his intentions to breach the Agreement.

Moreover, Walton and Does 1-100 were well aware of the fraudulent

nature of the transfer, for which they received no money or other

 

11

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3082]

consideration.

THIRD CAUSE OF ACTION

CONSPIRACY

(Against All Defendants)

40. Plaintiff realleges paragraphs 1-32 and 34-39,

inclusive, and incorporates them herein by reference.

41. As alleged above, in August, 1990, defendants

Armstrong, Walton, and Does 1 - 100 agreed, and knowingly and

willfully conspired between themselves to hinder, delay and

defraud plaintiff in the collection of its damages, and to render

Armstrong unable to pay any and all damages to plaintiff which

Armstrong had incurred and intended to and did incur in violation

of the Agreement.

42. Pursuant to this conspiracy, the above-named defendants

agreed that Walton and Does 1 - 100 would take ownership and/or

possession of all of defendant Armstrong's assets of any value,

including the above-described real property, cash and stock and

everything remaining from the proceeds of the settlement which

Armstrong had accepted from plaintiff pursuant to the Agreement.

Further, the defendants conspired and agreed to hide any and all

future assets acquired by Armstrong in the sham corporation, The

Gerald Armstrong Corporation, in order to protect Armstrong's

assets from collection so long as he was breaching the Agreement,

and plaintiff was attempting to collect damages for those

breaches. Plaintiff is unaware of the present value of those

assets which have been so hidden, but is informed and believes

and thereon alleges that their value exceeds $1,800,000, the

minimum value of plaintiff's claim.

 

12

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3083]

43. Defendants Armstrong, Walton, The Gerald Armstrong

Corporation and Does 1 - 100 did the acts and things herein

alleged pursuant to, and in furtherance of, the conspiracy and

agreement alleged above.

44. As a proximate result of the wrongful acts herein

alleged, plaintiff has been generally damaged in the sum of

$1,800,000.

45. At all times mentioned herein, defendants Walton,

Armstrong, The Gerald Armstrong Corporation and Does 1-100 knew

of defendant Armstrong's actions and intended actions against

plaintiff, knew of Armstrong's resultant obligation to

plaintiff, and knew that plaintiff's claims could only be

satisfied out of the property, sums and stock transferred by

Armstrong. Notwithstanding this knowledge, defendants Walton,

Armstrong, The Gerald Armstrong Corporation and Does 1-100

intentionally, willfully, fraudulently and maliciously did the

things herein alleged to defraud and oppress plaintiff.

Plaintiff is therefore entitled to exemplary or punitive damages

in the sum of $3,000,000 against all defendants, individually and

severally.

WHEREFORE, plaintiff prays for judgment as follows:

ON THE FIRST CAUSE OF ACTION

1. That the transfer of the real property from defendant

Armstrong to defendant Walton be set aside and declared void as

to the plaintiff herein to the extent necessary to satisfy

plaintiff's claim in the sum of $1,800,000 plus interest thereon

at the maximum rate permitted by law from 1990;

2. That defendant Walton be restrained from disposing of

 

13

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3084]

the property transferred;

3. That a temporary restraining order be granted plaintiff

enjoining and restraining defendant Walton, and his

representatives, agents, and attorneys from selling,

transferring, conveying, or otherwise disposing of any of the

property transferred;

4. That the judgment herein be declared a lien on the

property transferred;

5. That an order be made declaring that defendant Walton

holds all of the real property described above in trust for

plaintiff.

6. That defendant Walton be required to account to

plaintiff for all profits and proceeds earned from or taken in

exchange for the property described above.

ON THE SECOND CAUSE OF ACTION

1. That the transfer of assets from defendant Armstrong to

defendants Walton and Does 1 - 100 be set aside and declared void

as to the plaintiff herein to the extent necessary to satisfy

plaintiff's claim in the sum of $1,800,000 plus interest thereon

at the maximum rate permitted by law from 1990;

2. That defendants Walton, The Gerald Armstrong

Corporation and Does 1 - 100 be restrained from disposing of

the property transferred;

3. That a temporary restraining order be granted plaintiff

enjoining and restraining defendants Walton, The Gerald Armstrong

Corporation and Does 1 - 100, and their representatives, agents,

and attorneys from selling, transferring, conveying, or otherwise

disposing of any of the property transferred;

 

14

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3085]

4. That the judgment herein be declared a lien on the

property transferred;

5. That an order be made declaring that defendants Walton,

The Gerald Armstrong Corporation and Does 1-100 hold all of the

assets described above in trust for plaintiff.

6. That defendants Walton and Does 1 - 100 be required to

account to plaintiff for all profits and proceeds earned from or

taken in exchange for the property described above;

ON THE THIRD CAUSE OF ACTION

1. For general damages in the amount of $1, 800,000;

2. For exemplary or punitive damages in the sum of

$3,000,000;

ON ALL CAUSES OF ACTION AGAINST ALL DEFENDANTS

1. For attorneys fees and costs;

2. For such other and further relief as the court may deem

proper.

DATED: July 21, 1993

WILSON, RYAN & CAMPILONGO

By: [signed] Andrew Wilson
Andrew H. Wilson

Laurie J. Bartilson
BOWLES & MOXON

Attorneys for Plaintiff
CHURCH OF SCIENTOLOGY
INTERNATIONAL

 

15

 

 

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

 

[CT 3086]

VERIFICATION

I, ANDREW H. WILSON, declare as follows:

I am one of the attorneys for the Plaintiff Church of

Scientology International in the above-entitled matter. I have

read the foregoing Verified Complaint to Set Aside Fraudulent

Transsfers and for Damages; Conspiracy and know the contents

thereof, which are true of my own knowledge except as to those

matters which are stated on information and belief, and as to

those matters, I believe it to be true.

I declare under the penalty of perjury pursuant to the laws

of the State of California that the foregoing is true and

correct.

Executed on July 21, 1993 at San Francisco, California.

[signed]
ANDREW H. WILSON

 

16

   

    

Exhibit [A]
Mutual Release and Settlement Agreement

   

§   What's New   ||  Search   ||  Legal Archive  ||  Wog Media  ||  Cult Media  ||  CoW ® ||  Writings  ||  Fun  ||  Disclaimer  ||  Contact  §