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STATE OF CALIFORNIA 

County of Los Angeles
)
)    ss.
)

 

AFFIDAVIT OF GERALD ARMSTRONG

 

I, GERALD ARMSTRONG, being duly sworn, depose and state as

follows:

1. The following statements are made voluntarily, of my own free will,

and after full consultation with my attorneys,

Michael Flynn and Bruce Bunch.

2. I hereby acknowledge the consummation of a Mutual

Release and Agreement reached between myself and the Church of

Scientology International.

3. In accordance with the terms of said Mutual Release

and Agreement, I hereby state that I have returned to the

Church of Scientology International all "documents" of any

nature in my possession, custody or control relating to the

practices of Dianetics or Scientology, all evidence of any

nature acquired or retained for the purpose of any lawsuit or

for any other purpose concerning any Church of Scientology or

any of the other individuals or entities listed or referred

to in the Mutual Release and Agreement, any financial or

administrative materials concerning any church of Scientology

or any of the other individuals or entities listed or referred

to in the Mutual Release and Agreement, and any materials

relating to L. Ron Hubbard, his family, or his estate.

4. The term "documents" as used herein includes but is

not limited to all originals, copies and copies derived from

but not identical to the original, no matter how prepared, and

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all writings, papers, notes, records, books and other tangible

things including, by way of example and not of limitation, the

following:

     a. Memoranda, notes, calendars, appointment

books, shorthand or stenographer's notebooks,

correspondence, letters and telegrams, whether

received, sent, filed or maintained internally;

     b. Drafts or notes, whether typed, penciled

or otherwise, whether or not used;

     c. Minutes, reports or summaries of meetings;

     d. Contracts, agreements, understandings,

commitments, proposals or other business records;

     e. Recordings, transcriptions or memoranda or

notes made of any telephone or face-to-face oral

conversations between or among persons;

     f. Dictated tapes or other sound recordings;

     g. Computer printouts or reports and the

applicable program or programs therefor;

     h. Tapes, computer disks, cards, or any

other means by which data is stored or preserved

electrically, electronically, magnetically or

mechanically, and the applicable program or

programs therefor (from which the undersigned may

reproduce or cause to be reproduced such data in

written form);

     i. Pictures, drawings, photographs, slides,

films, negatives, charts or other graphic

representations;

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     j. Checks, bills, notes, receipts, or other

evidence of payment;

     k. Ledgers, journals, financial statements,

accounting records, operating statements, balance

sheets or statements of accounts.

     l. Any publications by the Church of

Scientology of California, by Bridge Publications,

or by New Era Publications, Inc. or any other

Church of Scientology or related entity or

individual.

5. [Handwritten] The Foregoing Excludes Attorney/Client Correspondence.
[End handwritten]

I declare under penalty of perjury under the laws of the

State of California that the foregoing is true and correct.

[signed] G. Armstrong
GERALD ARMSTRONG

 

Sworn and subscribed to before me
this 6th day of December, 1986,
At Los Angeles, California.

[signed] Jo-Ann Richardson
Notary Public for the State California

[notary seal]

 

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