Gerry Armstrong--Defendant Armstrong's First Production Request to Plaintiff Church of Scientology International

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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

DEFENDANT ARMSTRONG’S FIRST
PRODUCTION REQUEST TO PLAINTIFF
CHURCH OF SCIENTOLOGY
INTERNATIONAL

TO PLAINTIFF CHURCH OF SCIENTOLOGY INTERNATIONAL AND ITS

ATTORNEYS OF RECORD:

PROPOUNDING PARTY: Defendant GERALD ARMSTRONG

RESPONDING PARTY: Plaintiff CHURCH OF SCIENTOLOGY

INTERNATIONAL;

SET NO: ONE

Defendant Gerald Armstrong hereby propounds his First Request for Production of

Documents and Things pursuant to California Code of Civil Procedure §2031. You are required within

thirty (30) days to serve on the propounding party a written response responding separately to each

category listed below and to produce for inspection and photocopying all responsive documents at 10:00

A.M. on May 30, 2003, and continuing as long as reasonably required. The place of inspection shall be

the offices of Dialog Zentrum Berlin, Heimat 27, D-14165 Berlin-Zehlendorf Germany. Production by

mail of copies of the documents demanded herein may occur in lieu of personally appearing at the

location of the demanded inspection.

DEFINITIONS AND INSTRUCTIONS

As used herein:

1. The term “you” means: each and every “ beneficiary” or “releasee” of the “contract”

(“Mutual Release and Settlement Agreement”), which forms Exhibit A to your Complaint herein,

specifically, Church of Scientology International and each and every one of its officers, agents,

representatives, employees, volunteers, directors, successors, assigns and legal counsel; Church of

Scientology of California and each and every one of its officers, agents, representatives, employees,

volunteers, directors, successors, assigns and legal counsel; Religious Technology Center and each and

every one of its officers, agents, representatives, employees, volunteers, directors, successors, assigns

and legal counsel; each and every other Scientology organization and entity in the world including

Church of Spiritual Technology and each and every one of their officers, agents, representatives,

employees, volunteers, directors, successors, assigns and legal counsel; each and every Scientology

affiliated organization and entity in the world including Author Services, Inc. and each and every one of

their officers, agents, representatives, employees, volunteers, directors, successors, assigns and legal

counsel; L. Ron Hubbard, his heirs, beneficiaries, Estate and its executor; Author's Family Trust, its

beneficiaries and its trustee; and Mary Sue Hubbard.

2. The term "Documents" means: (a) any kind of writing as defined in California

Evidence Code §250 of any kind or description, whether sent or received or neither, including but not

limited to, all writings of any kind whether handwritten, typed, printed, recorded, webbed, digitized, or

otherwise produced, reproduced, or propagated, and including but not limited to all agreements,

contracts, letters, telegrams, teletypes, telexes, cables, faxes, e-mails, electronic transfers, inter-office

and intra-office communications, orders, compliances, reports, memoranda, notes, opinions,

recommendations, reviews, analyses, minutes, banks, special banks, estimates, summaries, evaluations,

plans, programs, missions, projects, briefings, debriefings, targets, cross-file sheets, battle plans, dead

agent documents or packs, black propaganda, entries in personal diaries or other record books,

summaries or notes of conversations or communications of any type or description (including, without

limitation, telephone conversations, personal conversations or interviews, meetings, conferences,

negotiations and investigations), marginal comments appearing in any documents, calendars, pamphlets,

books, manuals, directives, advices, bulletins, policy letters, news releases, advertisements, ledgers,

statistics, surveys, checks, financial statements, invoices, receipts, work sheets, opinions,

recommendations and analyses and all drafts of any of the foregoing writings; (b) all graphic,

mechanical, audio, video, magnetic, electronic productions, reproductions, representations, recordings or

compilations of data of any kind, including but not limited to, spreadsheets, data bases, drawings, charts,

graphs, motion picture film, microfilms, micro files, reels, cassettes, plates, photographs, slides, tapes or

other recordings, videotapes, punch cards, magnetic tapes, discs, data cells and drums, print-outs, drafts

and other data compilations from which information can be obtained (translated, if necessary, through

detection devices into usable form).

For purposes of the foregoing definitions, the term " drafts" means earlier, preliminary,

preparatory or tentative versions of all or part of a document, whether or not such draft was superseded

by a letter draft and whether or not the terms of the draft are the same as or different from the terms of

the final document; and the term "copies" of any documents means all versions of a document which are

not, in every respect, identical to the documents being produced.

3. All documents are to be produced in the file in which such documents have been

maintained in the order within each file in which such documents have been maintained.

3. The term “communications” includes any oral, written, electronic or visual contact

between two or more persons in which any information or opinion was exchanged, imparted or received.

4. In the event that any document called for by this Request has been destroyed or

discarded or otherwise disposed of, that document is to be identified as completely as possible, including

by providing, without limitation, the following information: date of disposal, manner of disposal, reason

for disposal, person authorizing the disposal and person disposing of the document.

5. This Request is intended to include all documents, as defined above, in the possession,

custody or control of each and all of the “ beneficiaries” or “releasees” described in Definition 1 above,

or their employees, agents, officers, or attorneys, located anywhere in the world, no matter by whom

such documents were prepared.

The following is the designation of the documents to be produced for inspection as above

stated:

1. All documents which in any way discuss, mention, concern, or relate to Gerald

Armstrong; or Gerry Armstrong; or any code name or designation identifying Gerald Armstrong used by

any of the “beneficiaries” or “releasees” described in Definition 1 above.

2. All documents which in any way discuss, mention, concern, or relate to any person

you, or any of you, at any time accused of “acting in concert” with defendant Armstrong, warned against

“acting in concert” with defendant Armstrong, or believed was or might be “acting in concert” with

defendant Armstrong, as the term “acting in concert” means and is used in the “ injunction” entered

against Armstrong in the case of Scientology v. Armstrong, Marin Superior Court Number 157680 on

October 17, 1995, including, but not limited to, Stephen Kent, PhD., Robert S. Minton, Stacy Brooks,

Robert Vaughn Young, Jeff Jacobsen, Arnaldo Lerma, Lawrence Wollersheim, Pastor Thomas

Gandow, Alexander Dvorkin, PhD., Keith Henson, Jesse Prince, Kennan Dandar, Esq., Ford Greene,

Esq., Caroline Letkeman, or any and all of these people by any other name or code name or designation.

DATED: April 19, 2003

GERRY ARMSTRONG

PROOF OF SERVICE

I am a citizen of Canada and reside in Germany. I am over the age of eighteen years and

am not a party to the within action. My business address is c/o Dialog Zentrum Berlin Heimat 27,

D-14165 Berlin-Zehlendorf, Germany.

I served the following document

DEFENDANT ARMSTRONG’S FIRST PRODUCTION REQUEST
TO PLAINTIFF CHURCH OF SCIENTOLOGY INTERNATIONAL

on the following persons on the date set forth below, by delivering a true copy thereof enclosed in a

sealed envelope to the addressees below:

Andrew H. Wilson, Esquire
WILSON CAMPILONGO LLP
475 Gate 5 Road
Sausalito, CA 94965
U.S.A.

Benjamin K. Riley, Esquire
COOLEY GODWARD LLP
One Maritime Plaza, 20th Floor
San Francisco, CA 94111-3580
U.S.A.

by causing such envelope with postage thereon fully prepaid to be placed in the Deutsche Post in

Germany.

I declare under penalty of perjury under the laws of Germany and the United States that

the above is true and correct.

Executed on April 23, 2003 in Germany, EU.

_________________
Caroline Letkeman

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