Gerry Armstrong--Armstrong Answer

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GERRY ARMSTRONG
C/O DIALOG ZENTRUM BERLIN
Heimat 27
D-14165 Berlin-Zehlendorf
Germany
Tel: +49(0)30-8157040
Fax: +49 (0) 1212-5-205-27-015
gerry@gerryarmstrong.org
In Propria Persona

SUPERIOR COURT OF CALIFORNIA

COUNTY OF MARIN

CHURCH OF SCIENTOLOGY

INTERNATIONAL,

Plaintiff,

vs.

GERALD ARMSTRONG, et al.,

Defendants.

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Case No. CV 021632

ANSWER OF GERRY ARMSTRONG

ANSWER

INTRODUCTION

Defendant Gerry Armstrong, hereinafter "Armstrong," hereby submits the following answer to

the complaint of plaintiff, Church of Scientology International, hereinafter "CSI." CSI is a single

component of the global Scientology organization, hereinafter "Scientology," that, along with all of the

Scientology-related beneficiaries of the settlement, which underlies their complaint that is answered

hereby, are subject to a unity of control exercised by David Miscavige, hereinafter " Miscavige." The

Scientology-related beneficiaries of the settlement, hereinafter the "beneficiaries," include, but are not

limited to, all Scientology and Scientology affiliated organizations and entities world wide, including

Church of Spiritual Technology, and their officers, agents, representatives, employees, volunteers,

directors, successors, assigns and legal counsel, including Sherman Lenske. Plaintiff and all other

Scientology-related organizations, entities and individual beneficiaries were created by David Miscavige

and his attorneys as an attempt to avoid payment of taxes and civil judgments and to confuse courts and

those seeking redress for the civil and criminal misconduct of Miscavige and all other Scientology-

related organizations, entities and individuals. Due to the unity of personnel, commingling of assets,

and commonality of business objectives, any effort by CSI to separate itself as being independent and

separate should be disregarded.

1. Armstrong admits that there was a Mutual Release of All Claims and Settlement

Agreement, hereinafter "mutual release," entered into in December 1986 between him and CSI,

Scientology, Miscavige and other beneficiaries of the mutual release. Armstrong denies that CSI,

Scientology, Miscavige or any of the beneficiaries have been damaged in any way whatsoever by

anything Armstrong has done at any time which could possibly be construed as a breach of the mutual

release. CSI's, Scientology's, Miscavige's and the beneficiaries' motive for bringing this action is not to

recover damages, because there have been and are no damages, but to destroy Armstrong pursuant to

CSI's, Scientology's, Miscavige's and the beneficiaries' basic philosophy, policy and practice of "fair

game" and their basic litigation policy of "using the law to harass and ruin utterly" their fair game

targets. Scientology founder L. Ron Hubbard, hereinafter " Hubbard," detailed by published policy how

CSI, Scientology, Miscavige and the beneficiaries are to treat fair game targets such as Armstrong:

"ENEMY - SP Order. Fair game. May be deprived of property or injured by any means by any

Scientologist without any discipline of the Scientologist. May be tricked, sued or lied to or

destroyed."

Armstrong has been designated an "enemy" of Scientology, Miscavige and all the beneficiaries and a

target of their fair game doctrine since 1981.

2. Armstrong denies that beginning in late 1989 he systematically began breaching virtually

every material covenant to which he had agreed by entering into the mutual release, or that at any time

he breached any material covenant whatsoever to which he had agreed by entering into the mutual

release. The conditions that CSI, Scientology, Miscavige and the beneficiaries characterize as "material

covenants" are not material at all, but against public policy, illegal, judicially unenforceable and

severable from the actual material covenants of the mutual release. Armstrong breached no material

covenant of the mutual release whatsoever, but performed each and every one of the material covenants

to which he had agreed by entering into the mutual release. Armstrong admits that in 1992, CSI

instituted suit against him, but denies that CSI, Scientology, Miscavige or the beneficiaries sought

damages for his repeated breaches of the mutual release, since there were no damages. Because of their

hatred for Armstrong, and pursuant to their fair game doctrine and policy of using the law to harass and

ruin utterly their fair game targets, CSI, Scientology, Miscavige and the beneficiaries sought to destroy

him by using the Law of the California Courts to enforce the mutual release's anti-public policy, illegal,

and immaterial conditions. Armstrong admits that CSI, Scientology, Miscavige and the beneficiaries

sought provisional and permanent injunctive relief against future breaches. Armstrong admits that CSI

obtained a monetary judgment and a permanent injunction in this Court. Armstrong admits that he has

characterized this Court's injunction as "illegal," "unconstitutional," and "a great stupidity," and he avers

that he has characterized the injunction moreover as impossible to perform, anti-public policy, anti-

American, anti-religion, diabolical, even insane. Armstrong further admits that because this Court's

injunction is illegal, unconstitutional, a great stupidity, impossible to perform, anti-public policy, anti-

American, anti-religion, diabolical, and even insane, Armstrong continually violates its terms.

Armstrong admits that he has been found by this Court to be in contempt on two separate occasions,

citing 14 separate violations, and is the subject of two outstanding bench warrants, but denies that this

was as a result of his beginning almost immediately to violate the terms of the injunction. Armstrong

was found by this Court to be in contempt on two separate occasions, citing 14 separate violations, and

is the subject of two outstanding bench warrants, as a result of this Court improperly, even illegally,

abetting CSI's, Scientology's, Miscavige's and the beneficiaries' fair gaming of Armstrong by illicitly

giving this Court's power and authority to CSI, Scientology, Miscavige and the beneficiaries to harass

and utterly ruin Armstrong, including by this Court's issuance of its illegal, unconstitutional, greatly

stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane

injunction. Armstrong admits that on July 13, 2001 he was again found to be in contempt of the

injunction on no less than 131 additional occasions. Armstrong also admits that on July 13, 2001 he was

found to be in contempt of the injunction on no more than 131 additional occasions. Armstrong denies

that he has evaded both the fines and the imprisonment to which he has been sentenced by fleeing the

jurisdiction and relocating to British Columbia, Canada. Armstrong left Marin County, California in

January 1997, because of unceasing fair game being perpetrated against him by CSI, Scientology,

Miscavige and the beneficiaries abetted by this Court, because of continuing threats to Armstrong's

livelihood, reputation and life by CSI, Scientology, Miscavige and the beneficiaries abetted by this

Court, and immediately at that time in January 1997 because of Armstrong's discovery of a lengthy fair

game "Black Propaganda," attack on him by CSI, Scientology, Miscavige and the beneficiaries in their

IRS Form 1023 Submission to the Internal Revenue on which their 1993 tax exemption is based. Black

Propaganda, hereinafter "black PR," is the term Hubbard directed be used and Scientology uses for its

policy and practice of destroying a fair game target's reputation, credibility and life with covert and

overt, relentless and pervasive libel and slander. CSI, Scientology, Miscavige and the beneficiaries

obtained their first fines and order of imprisonment against Armstrong from this Court, without notice to

him and based on false and misleading statements, many months after he had left Marin County and

relocated in British Columbia.

3. Armstrong denies that this action seeks redress for a total of 201 breaches of paragraph 7D

of the mutual release. This action seeks to illegally fair game Armstrong into silence, using the power

and authority and the appearance of legality, probity and justice of this Court, to punish Armstrong for

speaking the truth about CSI, Scientology, Miscavige and the beneficiaries and fair game, black PR, use

of the law to harass and ruin utterly, and their other illegal and noxious policies, practices and acts,and,

through the illegal fair gaming and illegal judicial silencing and punishing of Armstrong, to rewrite their

antisocial and criminal history which he knows and speak about. Armstrong admits that CSI,

Scientology, Miscavige and the beneficiaries assert claims for breach of contract against him and claims

for intentional interference with contractual relations against Robert Minton, hereinafter "Minton," and

the Lisa McPherson Trust, hereinafter the "LMT." Armstrong denies that the financial resources of

Minton or the LMT were intended to, and specifically enabled them to act in concert and conspiracy

with Armstrong to perpetuate his ongoing contempt of this Court and to violate on virtually a daily basis

CSI's contractual rights. Armstrong denies that CSI, Scientology, Miscavige or any of the beneficiaries

have any legal contractual right whatsoever to legally prevent Armstrong from doing anything he has

done, nor to legally prevent Minton or the LMT or anyone else from acting in concert and conspiracy, or

in concert, or in conspiracy, with Armstrong or without Armstrong, in doing anything he has done.

Whatever Armstrong has done is not contempt of this Court, because this Court's injunction is illegal,

unconstitutional, greatly stupid, impossible to perform, anti- public policy, anti-American, anti-religion,

diabolical and insane, and a person cannot legally be held in contempt of any court for violating an

injunction or any other court order which is illegal, unconstitutional, greatly stupid, impossible to

perform, anti-public policy, anti-American, anti-religion, diabolical and insane. Armstrong moreover

cannot either admit or deny CSI's averment that Minton's and the LMT's "financial resources were

intended to, and specifically enabled them to act in concert and conspiracy with Armstrong " because

this averment is unintelligible, nonsensical or both.

4. Armstrong admits that Plaintiff CSI's headquarters are located in Los Angeles, California,

and that it has been granted the status of a nonprofit religious corporation organized and existing under

the laws of the State of California. Armstrong denies that CSI is in fact a non-profit religious

corporation, but is a profit-driven cult of intelligence, utterly irreligious in nature and involved in

activities and practices antithetical to the laws of California, the United States, the world community,

and God.

5. Armstrong admits that he was a long-time resident of Marin County. He denies that he is

presently or has ever been a fugitive from this jurisdiction. Armstrong admits that he is a fugitive from

injustice. He admits that he is a fugitive from CSI's, Scientology's, Miscavige's and the beneficiaries'

illegal fair gaming of him abetted by this Court. Armstrong denies that Judge Thomas entered any

injunction on May 28, 1992. Armstrong denies that the orders of this Court finding him in contempt of

court concerned in any way violations of any injunction entered on May 28, 1992. Armstrong denies

that any of this Court's contempt of court orders against him were criminal contempt convictions.

Armstrong denies that he fled Marin County and relocated in Canada to avoid incarceration for any

criminal contempt convictions or from any orders of civil contempt. Armstrong avers that he was driven

from his home in Marin County in January, 1997 because of unceasing fair game being perpetrated

against him by CSI, Scientology, Miscavige and the beneficiaries abetted by this Court, because of

continuing threats to his livelihood, reputation and life by CSI, Scientology, Miscavige and the

beneficiaries abetted by this Court, and immediately at that time because of his discovery of a lengthy

fair game Black PR attack on him by CSI, Scientology, Miscavige and the beneficiaries in their IRS

Form 1023 Submission to the Internal Revenue on which their 1993 tax exemption is based. CSI,

Scientology, Miscavige and the beneficiaries obtained their first order of contempt against Armstrong

from this Court, without notice to him and based on false and misleading statements, many months after

he had left Marin County and relocated in British Columbia.

6. Armstrong admits that Minton is an individual. Armstrong lacks knowledge or information

sufficient to form a belief as to the truth of the averment that Minton maintains multiple residences in

Massachusetts, New Hampshire, Florida, and perhaps elsewhere, and is therefore unable to admit or

deny the same.

7. Armstrong denies that the LMT's name is either deceptive or misleading. Armstrong

admits that the LMT was a for-profit corporation, organized and existing under the laws of the State of

Florida, with its principal place of business in Clearwater, Florida. Armstrong lacks knowledge or

information sufficient to form a belief as to the truth of the averments that the LMT was dissolved in

December 2001 or that Minton is its founder, sole incorporator, and the source of its financing, and

Armstrong is therefore unable to admit or deny the same.

8. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the

averment that the LMT is, and at all times since its incorporation was, the alter ego of Minton and there

exists, and at all times since the LMT's incorporation has existed, a unity of interest and ownership

between these two defendants such that any separateness between them has ceased to exist, and

Armstrong is therefore unable to admit or deny the same. Armstrong denies that Minton has completely

controlled, dominated, managed and operated the LMT since its incorporation for his own personal

benefit.

9. Armstrong denies that the LMT is, and at all times herein mentioned was, a mere shell,

instrumentality and conduit through which defendant Minton carried on his own activities in the

corporate name, exercising such complete control and dominance of the activities of the LMT to such an

extent that any individuality or separateness of the LMT and Minton does not, and at all relevant times

mentioned herein, did not exist. Armstrong denies that the LMT made the barest pretense of adherence

to corporate formalities. Armstrong lacks knowledge or information sufficient to form a belief as to the

truth of the averment that Minton sold his entire interest in the LMT to Stacy Brooks, hereinafter

"Stacy," for the sum of one dollar, and is therefore unable to admit or deny the same. Armstrong lacks

knowledge or information sufficient to form a belief as to the truth of the averment that Stacy is

Minton's mistress, and is therefore unable to admit or deny the same. Armstrong denies that Minton

continues to exercise complete control over the LMT. Armstrong denies that Stacy ran the LMT's

affairs entirely under Minton's direction and for his benefit. Armstrong lacks knowledge or information

sufficient to form a belief as to the truth of the averment that Stacy is the President and sole shareholder

of LMT, and is therefore unable to admit or deny the same. Armstrong lacks knowledge or information

sufficient to form a belief as to the truth of the averment that following the nominal transfer of

ownership, Minton continued to finance the LMT's operations, and is therefore unable to admit or deny

the same. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the

averment that Minton's control of the LMT's finances was, or is, illustrated by the fact that he arranged

for anonymous donors to transfer in excess of $500,000 to the LMT's bank accounts, and is therefore

unable to admit or deny the same. Armstrong lacks knowledge or information sufficient to form a belief

as to the truth of the averments that upon receipt of any funds by the LMT, Stacy immediately paid them

out to Minton as a "repayment" of undocumented " loans" now claimed to be owed Minton by LMT, that

such undocumented loans existed, or did not exist, that Minton now claims he is owed anything by the

LMT, that Minton ever claimed he was owed anything by the LMT, or that anyone else is claiming or

ever claimed that Minton was owed anything by the LMT, and Armstrong is therefore unable to admit or

deny the same.

10. Armstrong denies that the separate existence of the LMT as an entity distinct and apart

from Minton is a fiction, and Armstrong therefore denies that any adherence to the fact of the separate

existence of the LMT as an entity distinct and apart from Minton would permit any abuse of the

corporate privilege or would promote any injustice. Armstrong lacks knowledge or information

sufficient to form a belief as to the truth of the averment that Minton has in any way used the LMT as a

means of financing, supporting, and enabling him to do anything, and is therefore unable to admit or

deny the same. Armstrong denies that anything Minton or the LMT have done to finance, support or

enable Armstrong does not finance, support or enable Armstrong to breach the mutual release on

virtually a daily basis, or on any other basis. Armstrong has performed each and every one of the

covenants to which he had agreed by entering into the mutual release, which were not illegal,

unconstitutional, greatly stupid, impossible to perform, anti- public policy, anti-American, anti-religion,

diabolical or insane.

11. Armstrong denies that the activities of the LMT and Minton are and have been regular and

systematic, or are or have been regular and systematic, or are and have been regular or systematic, or are

or have been regular or systematic, throughout California since its incorporation in 1999, or at any other

time. Armstrong denies that California was incorporated in 1999. Armstrong denies that indeed seven

of the LMT's key officials as identified in the LMT's own materials, are citizens and residents of

California. Armstrong denies that indeed seven of the LMT's key officials as identified in the LMT's

own materials, are not resident or officed in Florida. Armstrong denies that the LMT's own materials

identify seven key officials of all of its key or unkey officials from any or all states of the United States

or from any or all of the countries of the world. Armstrong denies that any members of the LMT's

Advisory Board are key officials in the LMT, or have ever been key officials in the LMT. Armstrong

lacks knowledge or information sufficient to form a belief as to the truth of the averments that seven

members of the LMT's Advisory Board are citizens and residents of California, or that any members of

the LMT's Advisory Board are citizens and residents of California, and Armstrong is therefore unable to

admit or deny the same. Armstrong lacks knowledge or information sufficient to form a belief as to the

truth of the averment that he himself is a member of LMT's Advisory Board, and is therefore unable to

admit or deny the same. Armstrong admits that he has in the past been a member of the LMT's

Advisory Board. Armstrong denies that he was ever or at any time a resident of Marin County or any

other California county on or after the date of incorporation of the LMT. Armstrong denies that he was

a Marin County resident until he absconded to Canada to avoid paying his fines and serving his jail time.

Armstrong repeats his averment that he was driven from his home in Marin County in January, 1997

because of unceasing fair game being perpetrated against him by CSI, Scientology, Miscavige and the

beneficiaries, abetted by this Court, because of continuing threats to his livelihood, reputation and life by

CSI, Scientology, Miscavige and the beneficiaries, abetted by this Court, and immediately at that time

because of his discovery of a lengthy fair game Black PR attack on him by CSI, Scientology, Miscavige

and the beneficiaries in their IRS Form 1023 Submission to the Internal Revenue on which their 1993

tax exemption is based. CSI, Scientology, Miscavige and the beneficiaries obtained their fines and jail

sentences against Armstrong from this Court, without notice to him and based on false and misleading

statements, many months after he had left Marin County and relocated in Canada. Armstrong denies

that the LMT is Minton's alter ego. Armstrong denies that flouting an injunction issued by this Court

which is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-

American, anti-religion, diabolical and insane directly or indirectly interferes in any way with the lawful

authority of the courts of the State of California. Armstrong denies that either Minton or the LMT

through any of their actions have in any way directly or indirectly interfered with the lawful authority of

the courts of the State of California.

12. Armstrong denies that at any time he combined, conspired or agreed with Minton or the

LMT to perform any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the

beneficiaries' complaint. Armstrong denies that any of the acts which are the subject of CSI's,

Scientology's, Miscavige's and the beneficiaries' complaint are unlawful. Armstrong denies that he

combined, conspired or agreed with Minton or the LMT to conceal from discovery any of the acts which

are the subject of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint. Armstrong

repeats his denial that any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the

beneficiaries' complaint are unlawful. Armstrong denies that he combined, conspired or agreed with

Minton or the LMT to conceal from discovery the participation of Minton and LMT, or Minton or the

LMT, in any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the

beneficiaries' complaint. Armstrong denies that any participation whatsoever of Minton or the LMT in

any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the beneficiaries'

complaint was unlawful or conspiratorial. Armstrong again repeats his denial that any of the acts which

are the subject of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint are unlawful.

13. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the

averment that the true names and capacities of the persons and/or entities that are sued by CSI,

Scientology, Miscavige or the beneficiaries as defendant DOES 1 through 50, inclusive, are unknown to

CSI, Scientology, Miscavige or the beneficiaries at this time, and Armstrong is therefore unable to admit

or deny the same. Armstrong lacks knowledge or information sufficient to form a belief as to the truth

of the averment that therefore CSI, Scientology, Miscavige or the beneficiaries are suing said defendants

by such fictitious names, and Armstrong is therefore unable to admit or deny the same. Armstrong lacks

knowledge or information sufficient to form a belief as to the truth of the averment that CSI,

Scientology, Miscavige or the beneficiaries will amend the complaint to show the true names and

capacities of defendant DOES 1 through 50, inclusive when the same are ascertained, and is therefore

unable to admit or deny the same. Armstrong denies that CSI, Scientology, Miscavige or the

beneficiaries are informed and believe that each of the DOE defendants is responsible in some manner

for the acts that CSI, Scientology, Miscavige or the beneficiaries complain of in their complaint.

Armstrong admits that CSI, Scientology, Miscavige and the beneficiaries just allege it.

14. Armstrong admits that on December 6, 1986 CSI, plus Scientology, plus Miscavige, plus

all the beneficiaries entered into a settlement with Armstrong, and that a true and correct copy of the

mutual release relating to such settlement is attached to CSI's, Scientology's, Miscavige's and the

beneficiaries' complaint as Exhibit A thereto and incorporated by reference therein. Armstrong denies

that the mutual release was designed to end, once and for all, or in any way, any litigation, bitter or not

bitter, including or not including several separate cases then pending. Armstrong denies that his

litigation against CSI, Scientology, Miscavige or any of the beneficiaries was bitter. Armstrong admits

that all of the litigations of CSI, Scientology, Miscavige and the beneficiaries were bitter, and were,

moreover, abusive, dishonest, unjust, threatening, hateful and diabolic. CSI, Scientology, Miscavige and

the beneficiaries designed the mutual release so they could continue their bitter, abusive, dishonest,

unjust, threatening, hateful and diabolic litigations against Armstrong and their other fair game targets,

continue their fair gaming of Armstrong and their other targets, continue to use the law to harass and

destroy utterly Armstrong and their other targets, and to rewrite their histories, without Armstrong being

able to respond in any way to CSI's, Scientology's, Miscavige's and the beneficiaries' bitter, abusive,

dishonest, unjust, threatening, hateful and diabolic litigations against Armstrong and their other fair

game targets, without Armstrong being able to respond to CSI's, Scientology's, Miscavige's and the

beneficiaries' continuing to fair game Armstrong and their other targets, without Armstrong being able

to respond to CSI's, Scientology's, Miscavige's and the beneficiaries' continuing to use the law to

harass and destroy utterly Armstrong and their other targets, and without Armstrong being able to

respond to CSI's, Scientology's, Miscavige's and the beneficiaries' rewriting of their histories; and to

harass, punish and utterly ruin Armstrong, using the power and authority and the appearance of legality,

probity and justice of the courts of California and the United States, if Armstrong responded in any way

to CSI's, Scientology's, Miscavige's and the beneficiaries' bitter, abusive, dishonest, unjust, threatening,

hateful and diabolic litigations against Armstrong and their other fair game targets, if he responded in

any way to CSI's, Scientology's, Miscavige's and the beneficiaries' continuing to fair game Armstrong

and their other targets, if he responded in any way to CSI's, Scientology's, Miscavige's and the

beneficiaries' continuing to use the law to harass and destroy utterly Armstrong and their other targets,

or if he responded in any way to CSI's, Scientology's, Miscavige's and the beneficiaries' rewriting of

their histories. Armstrong admits that he and CSI, plus Scientology, Miscavige and the beneficiaries

exchanged mutual, general releases. Armstrong denies that in consideration for a settlement payment of

$800,000 he and CSI, Scientology, Miscavige and the beneficiaries exchanged mutual, general releases.

Armstrong admits that paragraph 7D of the mutual release contains the following:

"Plaintiff agrees never to create or publish, or attempt to publish, and/or

assist another to create for publication by means of magazine, article, book

or other similar form, any writing or broadcast or to assist another to

create write, film, or video tape or audio tape any show, program or

movie, or to grant interviews or discuss with others, concerning their

experiences with the Church of Scientology, or concerning their personal

or indirectly acquired knowledge or information concerning the Church of

Scientology, L. Ron Hubbard or any of the organizations, individuals and

entities listed in Paragraph 1 above. Plaintiff further agrees that he will

maintain strict confidentiality and silence with respect to his experiences

with the Church of Scientology and any knowledge or information he may

have concerning the Church of Scientology, L. Ron Hubbard, or any of the

organizations, individuals or entities listed in Paragraph 1 above....

Plaintiff agrees that if the terms of this paragraph are breached by him,

that CSI and the other Releasees would be entitled to liquidated damages

in the amount of $50,000 for each such breach."

Armstrong denies that in consideration for a settlement payment of $800,000 he made the covenant

quoted above from paragraph 7D of the mutual release. Armstrong never agreed to any such "covenant"

because it is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-

American, anti-religion, diabolical and insane. Armstrong signed the mutual release containing said

illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti- American, anti-

religion, diabolical and insane "covenant" because of threats from CSI, Scientology, Miscavige and the

beneficiaries to the finances, health, businesses, families, reputations, persons and lives of himself, his

lawyers, his friends, and the non-Scientologist parties involved in several separate cases then pending

against CSI, Scientology, Miscavige or the beneficiaries; because of fraudulent representations by CSI,

Scientology, Miscavige, the beneficiaries, and Armstrong's lawyer; because of the compromise of

Armstrong's lawyer by CSI, Scientology, Miscavige and the beneficiaries; and because Armstrong was

guided by God to sign CSI's, Scientology's, Miscavige's and the beneficiaries' illegal, unconstitutional,

greatly stupid, impossible to perform, anti-public policy, anti- American, anti-religion, diabolical and

insane mutual release so that it could be shown to all the world to be exactly what it is, to wit, illegal,

unconstitutional, greatly stupid, impossible to perform, anti- public policy, anti-American, anti-religion,

diabolical, insane and clearly unenforceable. CSI, Scientology, Miscavige, the beneficiaries and all

Scientologists call all non-Scientologists "wogs," hereinafter "wogs," a Scientology hate term from the

organization's "scriptures" meaning "niggers." Armstrong is a wog.

15. Armstrong denies that beginning in late 1989, he began breaching his obligations under the

mutual release, including the terms of paragraph 7D. Armstrong performed all his obligations to which

he had agreed as stated in the mutual release. Since the terms of paragraph 7D of the mutual release are

illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti- American, anti-

religion, diabolical and insane, Armstrong had no obligation to perform such terms. Armstrong denies

that as a result of any breaching of any of his obligations CSI, Scientology, Miscavige or the

beneficiaries instituted Church of Scientology International v. Armstrong, Marin County Action No. VC

157680 against him, or any other suit against him. Armstrong denies that Church of Scientology

International v. Armstrong, Marin County Action No. VC 157680 is Armstrong I. Church of

Scientology International v. Armstrong, Marin County Action No. VC 157680 is Armstrong IV,

hereinafter "Armstrong IV." Scientology v. Armstrong, Los Angeles Superior Court Case No. C

420153 is Armstrong I, hereinafter "Armstrong I." CSI, Scientology, Miscavige and the beneficiaries

instituted Armstrong IV, Armstrong II, Armstrong III, Armstrong V, and the suit Armstrong is

answering here, Armstrong VII, against Armstrong as a result of their desire to fair game him into

silence using the power and authority and appearance of legality, probity and justice of the courts of

California and the United States; to harass, punish and ruin Armstrong utterly for speaking the truth

about CSI, Scientology, Miscavige and the beneficiaries and fair game, black PR, use of the law to

harass and ruin utterly, and their other illegal and noxious policies, practices and acts; and, through

CSI's, Scientology's, Miscavige's and the beneficiaries' illegal fair gaming and illegal judicial silencing,

harassing, punishing and utter ruining of Armstrong, to rewrite their antisocial and criminal history

which he knows and speak about. Armstrong admits that he cross- complained and that he alleged, and

still alleges that CSI, plus Scientology, plus Miscavige, plus the beneficiaries had violated the mutual

release. Armstrong denies that he alleged that the mutual release was void and unenforceable on a

variety of grounds. Armstrong alleged and still alleges that certain conditions of the mutual release are

void and unenforceable on a variety of grounds. Armstrong admits that his claims were all dismissed,

but denies that they were dismissed as unfounded. Armstrong's claims were dismissed because this

Court illegally and willfully abetted CSI's, Scientology's, Miscavige's and the beneficiaries' fair gaming

of Armstrong, illicitly gave its power and authority to CSI, Scientology, Miscavige and the beneficiaries

to harass and utterly ruin him, and improperly and legally impermissibly stripped Armstrong of his

defenses and rights. Armstrong admits that a judgment was entered in favor of CSI against him for

more than $500,000 in damages, interest, and costs. Armstrong admits that this Court entered a

judgment of injunction against him barring breaches by him of the conditions of the mutual release

which are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-

American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong denies that he

conveyed away all of the assets which he had. Armstrong admits that he gave away substantial cash and

a residence. Armstrong denies that he purchased the residence with the fruits of his $800,000

settlement. Armstrong denies that his settlement was $800,000. Armstrong denies that his settlement

had any fruits, except for the poison apples CSI, Scientology, Miscavige and the beneficiaries planted in

the "settlement." Armstrong admits that the monetary judgment CSI, Scientology, Miscavige and the

beneficiaries obtained against him was discharged in bankruptcy. Armstrong denies that he proceeded

to violate the injunction at will, or that he violates the injunction at will at any time. Armstrong admits

that he violates the injunction, which is illegal, unconstitutional, greatly stupid, impossible to perform,

anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, at the Will

of God. Armstrong admits that this Court issued contempt orders against him on June 3, 1997 and

February 11, 1998, respectively, and bench warrants with respect to those citations on August 6, 1997

and May 15, 1998. Armstrong denies that such contempt orders and warrants were the result of his

violation of the injunction, since the injunction is illegal, unconstitutional, greatly stupid, impossible to

perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable,

but such contempt orders and warrants were the result of this Court illegally and willfully abetting

CSI's, Scientology's, Miscavige's and the beneficiaries' fair gaming of Armstrong, illicitly giving its

power and authority to CSI, Scientology, Miscavige and the beneficiaries to harass and utterly ruin him,

and improperly and legally impermissibly stripping Armstrong of his defenses and rights. Armstrong

admits that true and correct copies of said orders and bench warrants are attached to CSI's,

Scientology's, Miscavige's and the beneficiaries' complaint and incorporated therein by reference as

Exhibits B and C respectively. Armstrong admits he was again found in contempt by order dated July

13, 2001. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the

averment that a true and correct copy of this order is attached to CSI's, Scientology's, Miscavige's and

the beneficiaries' complaint and incorporated therein by reference as Exhibit D and incorporated herein,

and is therefore unable to admit or deny the same.

16. Armstrong denies that his conduct after leaving the Scientology cult in 1981 has ever been

contumacious. Since this Court's injunction is illegal, unconstitutional, greatly stupid, impossible to

perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable,

Armstrong's violating said injunction can in no legally cognizable way be contumacious. If this Court's

illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti- American, anti-

religion, diabolical, insane and clearly unenforceable injunction had not been illegal, unconstitutional,

greatly stupid, impossible to perform, anti-public policy, anti- American, anti-religion, diabolical, insane

and clearly unenforceable, Armstrong's violating it could conceivably have been legally cognizable as

contumacious conduct; but that is not the case. Armstrong avers yet again that he left Marin County in

January, 1997 because of unceasing fair game being perpetrated against him by CSI, Scientology,

Miscavige and the beneficiaries, abetted by this Court, because of continuing threats to his livelihood,

reputation and life by CSI, Scientology, Miscavige and the beneficiaries, abetted by this Court, and

immediately at that time because of Armstrong's discovery of a lengthy fair game PR attack on him by

CSI, Scientology, Miscavige and the beneficiaries in their IRS Form 1023 Submission to the Internal

Revenue on which their 1993 tax exemption is based. Armstrong also avers yet again that CSI,

Scientology, Miscavige and the beneficiaries obtained their first contempt order against him from this

Court, without notice to him and based on false and misleading statements, many months after he had

left Marin County and relocated in British Columbia. Armstrong admits that since the February 1998

contempt order he made more than 200 oral statements and " postings" to the Internet newsgroup

alt.religion.scientology, hereinafter, "a.r.s." Armstrong denies that he made any statements created and

transmitted via e-mail and by "posting" to a.r.s. Armstrong admits that CSI, Scientology, Miscavige and

the beneficiaries allege that any oral statements he made or statements he posted to a.r.s., or any

statements created and transmitted via e-mail and by " posting" to a.r.s., should any such a thing exist,

are breaches of paragraph 7D of the mutual release and the explicit terms of the injunction. Armstrong

further admits that since the February 1998 contempt order he has made more than 100,000 statements,

oral or written, posted to a.r.s., or not posted to a.r.s., that CSI, Scientology, Miscavige and the

beneficiaries allege, will allege, or act as if they would allege, are breaches of paragraph 7D of the

mutual release and the explicit terms of the injunction. Armstrong avers that the conditions of paragraph

7D of the mutual release and the explicit terms of the injunction that would prohibit him from making

any of the statements he has made at any time are illegal, unconstitutional, greatly stupid, impossible to

perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable.

Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that

the date of each alleged breach of the more than 200 alleged breaches CSI, Scientology, Miscavige and

the beneficiaries are alleging is set forth in Exhibit E to their complaint, and Armstrong is therefore

unable to admit or deny the same. Armstrong denies that a short description of the substance of each

alleged breach of the more than 200 alleged breaches CSI, Scientology, Miscavige and the beneficiaries

are alleging is set forth in Exhibit E to their complaint. Armstrong admits that CSI, Scientology,

Miscavige and the beneficiaries have incorporated Exhibit E to their complaint therein by reference as if

set forth in full.

17. Armstrong admits that in December 1999 he traveled to Clearwater, Florida. Armstrong

denies that his travel to Clearwater was at the invitation of Minton or the LMT. Armstrong denies that

Minton and the LMT, or Minton or the LMT, paid for the expenses of his visit. Armstrong denies that

Minton or the LMT did anything in connection with his visit to Clearwater in December 1999 with the

purpose and intent of enabling Armstrong to violate the mutual release. Armstrong denies that Minton

or the LMT did anything in connection with his visit to Clearwater in December 1999 with the purpose

and intent of enabling Armstrong to make media and other public appearances as part of the LMT's anti-

Scientology campaign, or not as part of the LMT's anti-Scientology campaign. Armstrong denies that

the LMT had an anti-Scientology campaign. Armstrong believed and believes that the LMT had a

campaign of exposing and opposing Scientology abuses and criminality, such as Scientology's fair

gaming and black PRing of Armstrong and its use of the law to harass and ruin him utterly. Armstrong

admits that while in Clearwater he appeared at and addressed a gathering. Armstrong denies that the

gathering was assembled and sponsored by the LMT. Armstrong lacks knowledge or information

sufficient to form a belief as to the truth of the averment that the LTM produced a videotape of his

remarks to the gathering in Clearwater in 1999, and is therefore unable to admit or deny the same.

Armstrong denies that he began his videotaped remarks by acknowledging that his address was

prohibited by the injunction because he was so brazen. Armstrong began his videotaped remarks by

acknowledging that his address was prohibited by the injunction because the injunction is so illegal,

unconstitutional, greatly stupid, impossible to perform, anti- public policy, anti-American, anti-religion,

diabolical, insane and clearly unenforceable, because Armstrong was utterly certain of that fact, and

because he wanted to give any Scientologist, or wog, who might believe that such an injunction, which

prohibited a person from mentioning a religion or talking about his religious experiences, was not

illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti- American, anti-

religion, diabolical, insane and clearly unenforceable, the opportunity to leave the gathering.

18. Armstrong denies that he appeared on Radio Station WMNF-AM in Tampa, Florida while

still in Florida. Armstrong denies that he was in Florida on December 10, 1999. Armstrong denies that

he appeared on Radio Station WMNF-AM in Tampa, Florida at the request or expense of Minton or the

LMT. Armstrong admits that he gave an interview to that station. Armstrong admits that whatever he

said during said interview violated paragraph 7D. Armstrong avers again that the prohibitions of CSI's,

Scientology's, Miscavige's and the beneficiaries' paragraph 7D of their mutual release are illegal,

unconstitutional, greatly stupid, impossible to perform, anti- public policy, anti-American, anti-religion,

diabolical, insane and clearly unenforceable.

19. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the

averment that Minton is a self-appointed financial benefactor of persons such as Armstrong, and is

therefore unable to admit or deny the same. Armstrong denies that he is devoted to destroying the

Scientology religion, because he believes that irreligion, hatred and criminality, which are the attributes

of the Scientology cult he opposes and seeks to reform, are not religion. Armstrong denies that persons

such as him are also devoted to destroying the Scientology religion, because they too, being persons

such as him, believe irreligion, hatred and criminality, which are the attributes of the Scientology cult

they, being persons such as him, oppose and seek to reform, are not religion. Armstrong lacks

knowledge or information sufficient to form a belief as to the truth of the averment that Minton is the

sole incorporator of the LMT, and is therefore unable to admit or deny the same. Armstrong denies that

the LMT's purpose is or ever was the demise of the Scientology religion. Armstrong believes and has

always believed that the LMT's purpose was to expose, oppose and seek to reform attributes, policies or

practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and to assist

persons who have been victimized or targeted by Scientology's irreligious, dangerous, destructive,

abusive or criminal policies, practices and acts. Armstrong believed and believes that the following is a

true and correct statement of the reforms the LMT sincerely sought to bring about inside Scientology

and of the LMT's sincere support for religious beliefs and whatever is religious in Scientology:

The Lisa McPherson Trust started operations in Clearwater, Florida on

January 6, 2000. It was formed after decades of exhaustive investigation by

media and government agencies as well as firsthand accounts from hundreds

of former Scientologists. For more than twenty-five years there have been

outcries that the Church of Scientology abandon its abusive and deceptive

practices. But until now, there has been no formal organization committed to

stopping these abuses. The Lisa McPherson Trust was established for that

purpose, and we continue to demand that the Church of Scientology make the

following reforms:

__Tell their members and the public the truth about the life of Scientology

founder L. Ron Hubbard.

__Tell their members and the public the truth about the history of Dianetics

and Scientology.

__Cease all illegal, unethical and harassing activities against their own

members and those who criticize or disagree with Scientology.

__Revoke the policies and practices that violate the civil and human rights of

Scientologists and those who criticize or disagree with Scientology.

__Revoke the policy of practicing medicine without a license and preventing

people from receiving proper medical treatment.

__Stop using and abusing the legal system as a means of harassment.

__Stop keeping the technology of Scientology secret if it truly has the power

to help the human race.

__Encourage Scientologists to speak freely among themselves. Urge them to

communicate with family and friends, even those who may disagree with

Scientology. End the practice of "disconnection."

__Revoke the policy and practice of using private and personal material from

confidential counseling sessions to blackmail, harass and intimidate.

__Stop using duress to extract exorbitant sums of money from their members.

The Lisa McPherson Trust firmly believes in religious freedom for all. But

we do not believe that anyone has the right to engage in behavior that

violates other people's rights or the laws of the land. Scientologists have

every right to participate in the world's religious community in practicing

their sincerely held religious beliefs. However, Scientology needs to cease its

abusive and deceptive practices."

Armstrong denies that Minton's offer of $360,000 to achieve the revocation of the tax-exempt status of

Scientology and its components was a manifestation of Minton's commitment to harm and act against

the Scientology religion. Armstrong believed and believes that Minton's offer of $360,000 to achieve

the revocation of the tax-exempt status of Scientology and its components was a manifestation of

Minton's commitment to expose and oppose Scientology's irreligious, dangerous, destructive, abusive

or criminal policies, practices or acts and assist those persons who have been victimized or targeted by

such irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Scientology

obtained its tax exemption in 1993 by fraud, threat and other irreligious, dangerous, destructive, abusive

or criminal activities, including by the fair gaming and black PRing of Armstrong personally.

Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that

Minton made any offer in March of 1996, and is therefore unable to admit or deny the same. Armstrong

lacks knowledge or information sufficient to form a belief as to the truth of the averment that in

approximately March of 1996, Minton also gave substantial sums to California residents Grady Ward,

hereinafter "Ward," and Keith Henson, hereinafter " Henson," and is therefore unable to admit or deny

the same. Armstrong admits that Ward and Henson were defendants in copyright actions brought by

Scientology. Armstrong denies that the actions Scientology brought against Ward and Henson were to

protect Scientology's intellectual property rights, but were to illegally harass, punish and ruin Ward and

Henson utterly using the power and authority and appearance of legality, probity and justice of the U.S.

Justice system, and thus silence Ward and Henson about, and prevent them from exposing and speaking

the truth about, CSI, Scientology, Miscavige and the beneficiaries and fair game, black PR, use of the

law to harass and ruin utterly, and their other illegal and noxious policies, practices and acts.

20. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the

averment that in late 1997, Minton became a director of FACTNet, and is therefore unable to admit or

deny the same. Armstrong admits that FACTNet is a corporation. Armstrong denies that FACTNet's

purpose is to maintain a library of negative and misleading, often utterly false, materials

regarding the Church of Scientology. Armstrong believes and has always believed that FACTNet's

purpose is to be, inter alia, a library and research resource which maintains and makes publicly available

truthful materials about Scientology, which materials Scientology and its management willfully and

cruelly hide from and deny to Scientologists, and wogs, and attempt to destroy, particularly truthful

materials about Scientology's irreligious, dangerous, destructive, abusive or criminal policies and

practices, such as fair game, black PR and using the law to harass and ruin utterly Scientology's fair

game targets. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the

averment that in 1999 Minton resigned as a director of FACTNet and in November of that year formed

the LMT, and Armstrong is therefore unable to admit or deny the same.

21. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the

averments that Minton was first given notice or ever given notice of the mutual release and its terms by

letter dated January 14, 1998, by letter of any other date, or by any other means, on that date or any

other date, from counsel for CSI, or from any other person or entity, which enclosed or did not enclose a

copy of the permanent injunction issued against Armstrong " "and those acting in concert"" with him,

and Armstrong is therefore unable to admit or deny the same. Armstrong avers that the injunction and

the terms of the mutual release that the injunction purports to enforce are illegal, unconstitutional,

greatly stupid, impossible to perform, anti-public policy, anti- American, anti-religion, diabolical, insane

and clearly unenforceable as to Armstrong, and are no less illegal, unconstitutional, greatly stupid,

impossible to perform, anti-public policy, anti-American, anti- religion, diabolical, insane and clearly

unenforceable as to anyone, Scientologist or wog alike, " acting in concert" with Armstrong, or not

"acting in concert" with him.

22. Armstrong denies that CSI, Scientology, Miscavige or the beneficiaries fully ascertained

facts in the summer of 2000 upon which CSI, Scientology, Miscavige and the beneficiaries make their

averments contained in this paragraph. Armstrong admits that in January 1998 Minton loaned

Armstrong $90,000. Armstrong denies there was any secret agreement between him and Minton

regarding $25,000, or any of the $90,000. Armstrong denies that Minton gave or loaned him any money

whatsoever for the specific purpose, or unspecific purpose, of financing Armstrong's breaches of

paragraph 7D of the mutual release. Minton loaned money to Armstrong pursuant to Minton's public

offer of a monetary reward for the revocation of CSI's, Scientology's, Miscavige's and the beneficiaries'

IRS tax exemption, which was obtained by CSI, Scientology, Miscavige and the beneficiaries by illegal

means, including fraud involving the filing of black PR and false statements about Armstrong.

Armstrong's efforts to have CSI's, Scientology's, and the beneficiaries' IRS tax exemption revoked,

since such tax exemption was obtained by CSI, Scientology, Miscavige and the beneficiaries by illegal

means, including fraud involving the filing of black PR and false statements about Armstrong, and

Armstrong's efforts in communicating in any manner, form or medium about CSI, Scientology,

Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or

entities, or about exposing, opposing and seeking to reform attributes, policies, practices or acts of CSI,

Scientology, Miscavige and the beneficiaries which are irreligious, dangerous, destructive, abusive or

criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's,

Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or

criminal policies, practices or acts, cannot be legally prohibited, and the terms of paragraph 7D of CSI's,

Scientology's, Miscavige's and the beneficiaries' mutual release that prohibit such efforts and

communications by Armstrong, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-

public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong

believed and believes that Minton believed and believes that Armstrong's efforts to have CSI's,

Scientology's, and the beneficiaries' IRS tax exemption revoked, since such tax exemption was obtained

by CSI, Scientology, Miscavige and the beneficiaries by illegal means, including fraud involving the

filing of black PR and false statements about Armstrong, and Armstrong's efforts in communicating in

any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's

experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to

reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are

irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who

have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious,

dangerous, destructive, abusive or criminal policies, practices or acts, cannot be legally prohibited, and

the terms of paragraph 7D of CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release

that prohibit such efforts and communications by Armstrong, are illegal, unconstitutional, greatly stupid,

impossible to perform, anti-public policy, anti-American, anti- religion, diabolical, insane and clearly

unenforceable.

23. Armstrong admits that in or about December 1999, when the LMT was formed, Minton

invited him to become a member of the LMT's "Advisory Committee," hereinafter the "LMT Advisory

Committee." Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the

averment that Minton possessed the knowledge that Armstrong's participation in the LMT Advisory

Committee would of necessity involve a violation of the mutual release, and is therefore unable to admit

or deny the same. Armstrong admits that he had the knowledge that his participation in the LMT

Advisory Committee would of necessity involve a violation of the mutual release. Armstrong believed,

believes and avers that any of the terms of the mutual release that Armstrong's participation in the LMT

Advisory Committee would of necessity violate are illegal, unconstitutional, greatly stupid, impossible

to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable.

Armstrong believed and believes that Minton too believed and believes that any terms of the mutual

release which Armstrong's participation in the LMT Advisory Committee would of necessity violate are

illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti- American, anti-

religion, diabolical, insane and clearly unenforceable. Armstrong admits that he served on the LMT

Advisory Committee continuously through 2001. Armstrong denies that he and Minton, or he and the

LMT, or he and Minton and the LMT, or he and anyone formed or were involved in any way in an

conspiracy whatsoever as CSI, Scientology, Miscavige and the beneficiaries just allege. Armstrong

avers that because no such conspiracy ever existed as CSI, Scientology, Miscavige and the beneficiaries

just allege, nothing Armstrong or Minton or the LMT furthered one or could possibly further one.

Armstrong denies that the LMT possessed an anti-Scientology agenda. Armstrong believed and believes

that the LMT's agenda was to expose, oppose and seek to reform attributes or policies or practices of

Scientology which are irreligious, dangerous, destructive, abusive or criminal, and to assist persons such

as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive,

abusive or criminal policies, practices or acts. Armstrong believed and believes that the agenda of CSI,

Scientology, Miscavige and the beneficiaries, since their agenda is irreligious, dangerous, destructive,

abusive and criminal, is an anti-Scientology agenda because it puts Scientology and Scientologists at

immediate and extreme risk. Armstrong admits that he promoted the LMT's agenda of exposing,

opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious,

dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been

victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies,

practices or acts. Armstrong admits that he promoted through Internet postings as well as media and

other public appearances the LMT's agenda of exposing, opposing and seeking to reform attributes,

policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal,

and assisting persons such as Armstrong who have been victimized or targeted by Scientology's

irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, but Armstrong lacks

knowledge or information sufficient to form a belief as to the truth of the averment that through

hundreds of Internet postings he promoted the LMT's agenda, and is therefore unable to admit or deny

the same. The LMT's agenda of exposing, opposing and seeking to reform attributes, policies or

practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and assisting

persons such as Armstrong who have been victimized or targeted by Scientology's irreligious,

dangerous, destructive, abusive or criminal policies, practices or acts is also Armstrong's agenda, and he

has made thousands of Internet postings as well as media and other public appearances promoting that

agenda. Armstrong denies that the LMT was Minton's alter ego. Armstrong denies that either Minton

or the LMT was aware that Armstrong's primary means for violating paragraph 7D of the mutual release

was by e-mail and postings to a.r.s. Armstrong's primary means for communicating about exposing,

opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious,

dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been

victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies,

practices or acts is by speaking. Armstrong has been exposing, opposing and seeking to reform

attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or

criminal, and assisting persons such as Armstrong who have been victimized or targeted by

Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts by

speaking from at least 1980. Armstrong's secondary means for communicating about exposing,

opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious,

dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been

victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies,

practices or acts is by non-electronic writing. Armstrong has been exposing, opposing and seeking to

reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive,

abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by

Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts by non-

electronic writing from at least 1980. Armstrong has only been exposing, opposing and seeking to

reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive,

abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by

Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts by e-mail

or postings to a.r.s., his tertiary communication means for exposing, opposing and seeking to reform

attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or

criminal, and assisting persons such as Armstrong who have been victimized or targeted by

Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, since

l997. Any terms of paragraph 7D of the mutual release which Armstrong violated or violates by

speaking or writing, non-electronically or electronically, or by any other means or medium, in exposing,

opposing and seeking to reform attributes, policies or practices of Scientology or CSI or Miscavige or

the beneficiaries which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons

such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous,

destructive, abusive or criminal policies, practices or acts, are illegal, unconstitutional, greatly stupid,

impossible to perform, anti-public policy, anti-American, anti- religion, diabolical, insane and clearly

unenforceable. Armstrong admits that in or about December of 1999, Minton purchased a computer for

Armstrong. Armstrong denies that the LMT purchased a computer for him. Armstrong denies that the

LMT is Minton's alter ego. Armstrong denies that Minton purchased a computer for him for the specific

purpose of using it to make publications of writings about CSI and other beneficiaries of the mutual

release in violation of that mutual release and in furtherance of the conspiratorial scheme CSI,

Scientology, Miscavige and the beneficiaries have just alleged in their complaint. Armstrong denies that

the conspiratorial scheme CSI, Scientology, Miscavige and the beneficiaries have just alleged in their

complaint exists or has ever existed. Armstrong denies that Minton purchased a computer for him for

the specific purpose of using it to make publications of writings of any kind about anyone or anything.

Armstrong admits that virtually any personal computer can be used to make publications of writings of

any kind about anyone or anything. Armstrong denies that he has ever testified in any proceeding that

Minton knew at the time that the computer would be used in the fashion CSI, Scientology, Miscavige

and the beneficiaries have just alleged in their complaint. Armstrong denies that Minton knew at the

time that the computer would be used in the fashion CSI, Scientology, Miscavige and the beneficiaries

have just alleged in their complaint. Armstrong denies that the computer would ever be used, was ever

used, is being used or will ever be used in the fashion CSI, Scientology, Miscavige and the beneficiaries

have just alleged in their complaint. Armstrong denies that he has ever testified in any proceeding that

Minton gave the computer to Armstrong for exactly the purpose CSI, Scientology, Miscavige and the

beneficiaries have just alleged in their complaint. Armstrong denies that Minton gave the computer to

Armstrong for exactly the purpose CSI, Scientology, Miscavige and the beneficiaries have just alleged

in their complaint. Armstrong denies that the computer was ever used, is being used or will ever be used

for exactly the purpose CSI, Scientology, Miscavige and the beneficiaries have just alleged in their

complaint. Armstrong denies that he has ever testified in any proceeding that Minton knew he was

giving the computer to Armstrong for any unlawful purpose whatsoever. Armstrong denies that Minton

gave the computer to Armstrong for any unlawful purpose whatsoever. Armstrong denies that the

computer was ever used, is being used or will ever be used for any unlawful purpose whatsoever.

Armstrong denies that using the computer, or any computer, to make publications of writings about CSI

and other beneficiaries, or about Scientology, or about Miscavige, or about Armstrong's experiences in

relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes

or policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are irreligious,

dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been

victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious,

dangerous, destructive, abusive or criminal policies, practices or acts, is an unlawful purpose.

Armstrong denies that violating terms of the mutual release which are illegal, unconstitutional, greatly

stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and

clearly unenforceable, such as paragraph 7D of the mutual release, is in any way whatsoever unlawful.

24. Armstrong admits that in June 2000 he traveled to Germany to attend a public ceremony

where Minton was presented with an award. Armstrong denies that Minton was presented an award for

any anti-Scientology activities. Minton was presented an award at a public ceremony in Germany for

his contributions in exposing, opposing and seeking to reform attributes or policies or practices of CSI,

Scientology, Miscavige and the beneficiaries which are irreligious, dangerous, destructive, abusive or

criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's,

Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal

policies, practices or acts. Armstrong denies that exposing, opposing and seeking to reform attributes,

policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are irreligious,

dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been

victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious,

dangerous, destructive, abusive or criminal policies, practices or acts constitutes any anti- Scientology

activity, unless Scientology is only a completely irreligious, completely dangerous, completely

destructive, completely abusive and completely criminal enterprise containing only completely

irreligious, completely dangerous, completely destructive, completely abusive, completely criminal and

completely irredeemable policies, practices, acts and personnel. Armstrong denies that Scientology is

only a completely irreligious, completely dangerous, completely destructive, completely abusive and

completely criminal enterprise containing only completely irreligious, completely dangerous,

completely destructive, completely abusive, completely criminal and completely irredeemable policies,

practices, acts and personnel. Armstrong denies that Minton was presented the award in Europe in 2000

by a small group of like-minded extremists. Armstrong denies that Minton is an extremist. Armstrong

denies that he is an extremist. Armstrong denies that any member of the group which presented the

award to Minton is an extremist. The group which presented the award to Minton is the European-

American Citizens Committee for Human Rights and Religious Freedom in the USA, hereinafter, the

"Committee." Armstrong is a member of the Committee. Armstrong admits that Minton and the

Committee have been to a degree like-minded in their dedication to exposing, opposing and seeking to

reform attributes or policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are

irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who

have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious

dangerous, destructive, abusive or criminal policies, practices or acts. Armstrong admits that during this

trip he met with media representatives and communicated about CSI, Scientology, Miscavige or the

beneficiaries and about exposing, opposing and seeking to reform their attributes or policies or practices

which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as

Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the

beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts.

Armstrong admits that communicating about CSI, Scientology, Miscavige or the beneficiaries or about

exposing, opposing and seeking to reform their attributes or policies or practices which are irreligious,

dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been

victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious,

dangerous, destructive, abusive or criminal policies, practices or acts is a breach of certain terms of the

mutual release. Armstrong believed, believes, and again avers that any terms of the mutual release

which prohibit him or anyone from communicating about CSI, Scientology, Miscavige or the

beneficiaries or about exposing, opposing and seeking to reform their attributes or policies or practices

which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as

Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the

beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, are

illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti- American, anti-

religion, diabolical, insane and clearly unenforceable. Armstrong admits that these travels were in part

financed and supported by Minton. Armstrong denies that these travels were financed in any part by the

LMT. Armstrong denies that the LMT is or was Minton's alter ego. Armstrong denies that either

Minton or the LMT financed Armstrong's meeting with any media representatives or financed

Armstrong's engaging in any of his actions of communicating about CSI, Scientology, Miscavige or the

beneficiaries or about exposing, opposing and seeking to reform their attributes, policies or practices

which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as

Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the

beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, which

CSI, Scientology, Miscavige and the beneficiaries are alleging constitute breaches of the mutual release.

Armstrong denies that Minton possessed the knowledge at any time that Armstrong would meet with

media representatives and engage in actions of communicating about CSI, Scientology, Miscavige or the

beneficiaries or about exposing, opposing and seeking to reform their attributes or policies or practices

which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as

Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the

beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, which

CSI, Scientology, Miscavige and the beneficiaries are alleging constitute breaches of the mutual release;

or that Minton possessed the knowledge at any time that Armstrong would use this or any other

opportunity to further communicate about CSI, Scientology, Miscavige or the beneficiaries or exposing,

opposing or seeking to reform their attributes or policies or practices which are irreligious, dangerous,

destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or

targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive,

abusive or criminal policies, practices or acts, or in any other way violate the mutual release. Armstrong

admits that Minton and the LMT supported his exposing, opposing and seeking to reform CSI's,

Scientology's, Miscavige's and the beneficiaries' attributes, policies and practices which are irreligious,

dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been

victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious,

dangerous, destructive, abusive or criminal policies, practices or acts.

25. Armstrong denies that from May through July of 2001 he traveled to Russia, Germany,

Denmark, the United Kingdom and other countries. Armstrong admits that from April to June 2001 he

traveled to Russia, Germany, Denmark, the United Kingdom and other countries. Armstrong admits that

during the period of May to July 2001 he met with media personnel and made numerous public

statements about CSI, Scientology, Miscavige or the beneficiaries and about exposing, opposing and

seeking to reform their attributes, policies or practices which are irreligious, dangerous, destructive,

abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by

CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or

criminal policies, practices or acts. Armstrong admits that making public statements about CSI,

Scientology, Miscavige or the beneficiaries and about exposing, opposing and seeking to reform their

attributes, policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and

assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's,

Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies,

practices or acts, is a violation of certain terms of the mutual release. Armstrong believed, believes, and

again avers that any terms of the mutual release that prohibit him or anyone from making public

statements about CSI, Scientology, Miscavige or the beneficiaries and exposing, opposing and seeking

to reform their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or

criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's,

Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal

policies, practices or acts, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public

policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong admits

that his travels during April, May and June 2001 were in part financed and supported by Minton.

Armstrong denies that these travels were financed in any part by the LMT. Armstrong denies that the

LMT is or was Minton's alter ego. Armstrong denies that either Minton or the LMT financed any of

Armstrong's actions of meeting with any media personnel or of making any public statements about

CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform

their attributes or policies or practices which are irreligious, dangerous, destructive, abusive or criminal,

and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's,

Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies,

practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute

violations of the mutual release. Armstrong denies that Minton possessed the knowledge at any time

that Armstrong would meet with media personnel and make numerous or any public statements about

CSI, Scientology, Miscavige or the beneficiaries and about exposing, opposing and seeking to reform

their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or criminal,

and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's,

Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies,

practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute

breaches of the mutual release; or that Minton possessed the knowledge at any time that Armstrong

would use this or any other opportunity to make numerous or any public appearances where such

statements about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and

seeking to reform their attributes, policies or practices which are irreligious, dangerous, destructive,

abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by

CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or

criminal policies, practices or acts, occurred. Armstrong admits that he was in Leipzig, Germany and

publicly appeared with Minton, Stacy, and other LMT employees. Armstrong admits that in Leipzig he

made public statements about CSI, Scientology, Miscavige and the beneficiaries and about exposing,

opposing and seeking to reform their attributes, policies or practices which are irreligious, dangerous,

destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or

targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive,

abusive or criminal policies, practices or acts, and that such public statements violate certain terms of the

mutual release. Armstrong denies that Minton possessed the knowledge at any time that Armstrong

would make the public statements Armstrong made or that Armstrong would make any public

statements in Leipzig about CSI, Scientology, Miscavige or the beneficiaries or about exposing,

opposing and seeking to reform their attributes, policies or practices that are irreligious, dangerous,

destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or

targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive,

abusive or criminal policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries

are alleging constitute violations of the mutual release. Any terms of the mutual release that prohibit

Armstrong, anyone acting in concert with him, or anyone else, from making the public appearances and

public statements that Armstrong made in Leipzig, or anywhere else in Europe, or anywhere else in the

world, about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking

to reform their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or

criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's,

Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal

policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging

constitute violations of the mutual release, are illegal, unconstitutional, greatly stupid, impossible to

perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable.

Armstrong believed and believes that Minton too believed and believes that the terms of the mutual

release that prohibit Armstrong, anyone acting in concert with him, or anyone else, from making the

public appearances and public statements that Armstrong made in Leipzig, anywhere else in Europe, or

anywhere else in the world, about CSI, Scientology, Miscavige or the beneficiaries or about exposing,

opposing and seeking to reform their attributes or policies or practices which are irreligious, dangerous,

destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or

targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive,

abusive or criminal policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries

are alleging constitute violations of the mutual release, are illegal, unconstitutional, greatly stupid,

impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly

unenforceable. Armstrong admits that Minton and the LMT supported Armstrong's exposing, opposing

and seeking to reform CSI's, Scientology's, Miscavige's and the beneficiaries' attributes, policies or

practices that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as

Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the

beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts.

Armstrong admits that although Minton encouraged Armstrong's exposing, opposing and seeking to

reform CSI's, Scientology's, Miscavige's and the beneficiaries' attributes, policies or practices that are

irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who

have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious,

dangerous, destructive, abusive or criminal policies, practices or acts, at no time did Minton encourage

Armstrong in any violations of the mutual release. Armstrong repeats that he believed and believes that

Minton too believed and believes that the terms of the mutual release that prohibit Armstrong, anyone

acting in concert with him, or anyone else from making public statements about CSI, Scientology,

Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes or

policies or practices that are irreligious, dangerous, destructive, abusive or criminal, and assisting

persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's

and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts,

which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute violations of the mutual

release, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-

American, anti-religion, diabolical, insane and clearly unenforceable.

FIRST CAUSE OF ACTION

(Breach of Contract Alleged of Gerald Armstrong)

26. In answering the averments contained in this paragraph wherein CSI, Scientology,

Miscavige and the beneficiaries incorporate by reference their averments contained in paragraphs 1

through 25, inclusive, of their complaint, Armstrong admits, denies and avers to the same effect and in

the same manner as he admitted, denied and averred with respect to those specific paragraphs as

previously set forth in this answer.

27. Armstrong denies that by reason of the facts alleged in paragraphs 15, 16, and 17 of CSI's,

Scientology's, Miscavige's and the beneficiaries' complaint Armstrong has committed 201 separate and

distinct breaches of paragraph 7D of the mutual release. By reason of the facts alleged in paragraphs 15,

16, and 17 of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint, Armstrong has

committed 204 separate and distinct breaches of paragraph 7D of the mutual release, plus more than

99,796 more separate and distinct breaches of paragraph 7D of the mutual release, for a grand total of

more than 100,000 separate and distinct breaches of paragraph 7D of the mutual release. Armstrong

denies that as a result of any facts alleged by CSI, Scientology, Miscavige and the beneficiaries in their

complaint, or as a result of anything Armstrong has done or not done at any time, CSI, Scientology,

Miscavige or the beneficiaries are entitled to liquidated damages of $50,000 for each such breach, or

even that $50,000 for each such breach totals $10,050,000. By reason of the facts stated by Armstrong

herein, neither CSI, Scientology, Miscavige nor any of the beneficiaries are entitled to even one red cent

in liquidated damages, or damages from Armstrong of any amount or kind whatsoever.

SECOND CAUSE OF ACTION

(Intentional Interference with Contractual Relations

Alleged Against Robert Minton and the LMT)

28. In answering the averments contained in this paragraph wherein CSI, Scientology,

Miscavige and the beneficiaries incorporate by reference their averments contained in paragraphs 1

through 25, inclusive, and paragraph 27 of their complaint, Armstrong admits, denies and avers to the

same effect and in the same manner as he admitted, denied and averred with respect to those specific

paragraphs as previously set forth in this answer.

29. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the

averment that by reason of the facts set forth in CSI's, Scientology's, Miscavige's and the beneficiaries'

complaint, Minton and the LMT, or Minton or the LMT, has or ever had knowledge and notice of both

the mutual release and the injunction, and Armstrong is therefore unable to admit or deny the same.

Armstrong denies that by reason of the facts set forth in CSI's, Scientology's, Miscavige's and the

beneficiaries' complaint, Minton and the LMT, or Minton or the LMT, willfully, deliberately, and

maliciously aided and financially rewarded and enabled Armstrong, or willfully, or deliberately, or

maliciously aided or financially rewarded or enabled Armstrong, to breach his contractual obligations,

as alleged in paragraphs 15, 16, 17, and 24 of CSI's, Scientology's, Miscavige's and the beneficiaries'

complaint. The terms of the mutual release that Armstrong at any time breached by communicating in

any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's

experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to

reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries that are

irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who

have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious,

dangerous, destructive, abusive or criminal policies, practices or acts, are illegal, unconstitutional,

greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane

and clearly unenforceable, and Armstrong therefore had no legally cognizable contractual obligation to

not breach those terms. Armstrong believed and believes that Minton and the LMT also believed and

believe that the terms of the mutual release which Armstrong at any time breached by communicating in