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MUTUAL RELEASE AGREEMENT

1. This MUTUAL RELEASE AGREEMENT is made and entered into

by and between VICKI AZNARAN and the Religious Technology

Center; Church of Scientology International; Church of

Scientology of California; Church of Spiritual Technology; all

other Scientology organizations or entities as well as the

officers, agents, representatives, employees, volunteers,

trustees, directors, successors, assigns, and legal counsel of

each of the forgoing organizations or entities; Pat Broeker

and Anne Broeker (hereinafter collectively referred to as the

"CHURCH"); and Author Services Incorporated, it's officers,

agents, representatives, employees, volunteers, trustees,

directors, successors, assigns and legal counsel; the Estate

of L. Ron Hubbard, it's executor, beneficiaries, legal

counsel and employees; Author's Family Trust, it's trustee,

employees, beneficiaries, and legal counsel (hereinafter

collectively referred to as the "ESTATE/ASI").

2. The CHURCH agrees to indemnify VICKI AZNARAN against

any damages stemming from lawsuits which exist now or are

brought against her in the future arising out of her

association with the Church of Scientology or any posts she

has held in the Church. It is understood that as a part of

this agreement the CHURCH will provide free legal counsel to

VICKI AZNARAN providing she cooperates fully with the CHURCH

and CHURCH attorneys and she contacts the CHURCH immediately

when she becomes aware of any potential or real legal threat

to herself and/or the CHURCH.

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3. For and in consideration of the above mutual

covenants, conditions and release contained herein, VICKI

AZNARAN does hereby release, acquit and forever discharge for

herself, her heirs, successors, executors, administrators and

assigns, the CHURCH and the ESTATE/ASI from any and all

claims, demands, damages, actions and causes of action of

every kind and nature, known or unknown, from the beginning of

time to and including the date hereof.

4. For and in consideration of the mutual covenants,

conditions and release contained herein, the CHURCH and the

ESTATE/ASI do hereby release, acquit and forever discharge for

it, its successors and assigns, VICKI AZNARAN, her agents,

representatives, heirs, successors, assigns, legal counsel and

estate and each of them, of and from any and all claims,

causes of action, demands, damages and actions of every kind

and nature, known or unknown, for or because of any act or

omission allegedly done by VICKI AZNARAN from the beginning of

time to and including the date hereof.

5. It is understood that this mutual release is not an

admission of liability on the part of any party to this

Agreement. In executing this Release Agreement, VICKI AZNARAN

acknowledges that she has released the organizations,

individuals and entities listed in Paragraph 1.

6. Further, the undersigned hereby agree to the

following:

A. That liability for any claims is expressly denied by

each party herein released, and this Agreement shall never be

treated as an admission of liability or responsibility at any

time for any purpose.

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B. VICKI AZNARAN has been fully advised and understands

that any alleged injuries or alleged money claims sustained by

her are of such character that the full extent and type of

injuries or money claims may not be known at the date hereof,

and it is further understood that said alleged injuries,

whether known or unknown at the date hereof, might possibly

become progressively worse and that as a result, damages may

be sustained by VICKI AZNARAN; nevertheless, VICKI AZNARAN

desires by this document to forever and fully release the

CHURCH and the ESTATE/ASI. VICKI AZNARAN understands that by

the execution of this release no claims arising out of her

experience with, or actions by, the CHURCH and the ESTATE/ASI,

from the beginning of time to and including the date hereof,

which may now exist or which may exist in the future may ever

be asserted by her or on her behalf, against the CHURCH and

the ESTATE/ASI.

C. VICKI AZNARAN 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 to broadcast, or to assist

another to create, write, film or video tape or audio tape,

any show, program or movie, concerning her experiences with

the Church of Scientology, or personal or indirectly acquired

knowledge or information concerning the Church of Scientology,

L. Ron Hubbard, or any entities and individuals listed in

Paragraph 1 above. VICKI AZNARAN further agrees that she will

maintain strict confidentiality and silence with respect to

her experience's with the Church of Scientology and any

knowledge or information she may have concerning the Church of

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

individuals and entities listed in Paragraph 1 above. VICKI

AZNARAN expressly understands that the non-disclosure

provisions of this subparagraph shall apply, but not be

limited to, the contents or substance of any documents she may

have possessed while in the Church including but not limited

to any tapes, films, photographs, or variations thereof which

concern or relate to the religion of Scientology, L. Ron

Hubbard, or any of the organizations, individuals, or entities

listed in Paragraph 1 above. VICKI AZNARAN agrees that if the

terms of this paragraph are breached by her, that the

aggrieved party listed hereinabove would be entitled to

liquidated damages in the amount of $10,000 for each such

breach. The reasonableness of the amount of such damages are

hereto acknowledged by VICKI AZNARAN.

D. VICKI AZNARAN agrees to return to the CHURCH at the

time of the consummation of this Agreement, all materials in

her possession, custody or control of any nature - except for

any materials she personally possesses that are generally

publically available and sold by the Church or their

authorized agents - any documents, papers, memorandums, tapes,

films, photographs, or any variations thereof which concern or

relate to the religion of Scientology or any of the persons or

entities listed in Paragraph 1 above.

E. VICKI AZNARAN agrees that she will not voluntarily

assist or cooperate with any person adverse to the religion of

Scientology in any proceeding against any of the Scientology

organizations, or cooperate with any person adverse to

any of the organizations, individuals or entities listed in

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Paragraph 1 above in any proceeding against any of the

organizations, individuals, or entities listed in Paragraph 1

above. VICKI AZNARAN also agrees that she will not cooperate

in any manner with any organizations aligned against

Scientology or any of the organizations, individuals, or entities listed

in Paragraph 1 above.

F. VICKI AZNARAN agrees not to testify or otherwise

participate in any other judicial, administrative or

legislative proceeding adverse to Scientology or any of the

organizations, individuals or entities listed in Paragraph 1

above unless compelled to do so by lawful subpoena or other

lawful process. Unless required to do so by such subpoena,

VICKI AZNARAN agrees not to discuss her experiences or

personal or indirectly acquired knowledge or information

concerning the organizations, individuals, or entities listed

in Paragraph 1, with anyone other than members of her

immediate family. VICKI AZNARAN shall not make herself

amenable to service of any such subpoena in a manner

which invalidates the intent of this agreement. As provided

hereinafter in Paragraph 16, the contents of this Agreement

may not be disclosed.

G. VICKI AZNARAN hereby acknowledges and affirms that

she is not under the influence of any drug, narcotic,

alcohol or other mind-influencing substance, condition or ailment such

that her ability to fully understand the meaning of this

Agreement and the significance thereof is adversely affected.

7. This Release Agreement contains the entire Agreement

between the parties hereto, and the terms of this Release are

contractual and not a mere recital. This Release may be

-5-

 

amended only by a written instrument executed by the

undersigned. The parties hereto have carefully read and

understand the contents of this Release Agreement and sign the

same of their own free will, and it is the intention of the

parties to be legally bound hereby. No other prior or

contemporaneous agreements, oral or written, respecting such

matters, which are not specifically incorporated herein shall

be deemed to in any way exist or bind any of the parties

hereto.

8. VICKI AZNARAN agrees that she will not assist or

advise anyone, including partnerships, associations or

corporations, contemplating any claim or engaged in litigation

or involved in or contemplating any activity adverse to the

interests of any entity or class of persons listed above in

Paragraph I of this Agreement.

9. The parties to this Agreement acknowledge that all

parties enter into this Agreement freely, voluntarily,

knowingly and willingly, without any threats, intimidation or

pressure of any kind whatsoever and voluntarily execute this

Agreement of their own free will.

10. In the event any provision hereof is unenforceable,

such provision shall not affect the enforceability of any

other provision hereof.

11. Each party warrants that it has had an opportunity

to seek independent legal advice with respect to the

advisability of making the settlement provided for herein and

in executing this Agreement. Notwithstanding, VICKI

AZNARAN warrants that she fully understand the full nature and legal

consequences of this agreement.

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12. The parties to this Agreement acknowledge that all

parties have conducted sufficient deliberation and

investigation, either personally or through other sources of

their own choosing, and have had the opportunity to seek

advice of counsel regarding the terms and conditions set forth

herein, so that they may intelligently exercise their own

judgment in deciding whether or not to execute this Agreement.

13. The parties hereto acknowledge that they have not

made any statement, representation or promise to the other

party regarding any fact material to this Agreement except as

expressly set forth herein. Furthermore, except as expressly

stated in this Agreement, the parties in executing this

Agreement do not rely upon any statement, representation or

promise by the other party or of any officer, agent, employee,

representative or attorney for the other party.

14. The parties to this Agreement agree that all parties

have carefully read this Agreement and understand the contents

thereof and that each reference in this Agreement to any party

includes successors, assigns, principals, agents and employees

thereof.

15. Each party warrants that the persons signing this

Agreement have the full right and authority to enter into this

Agreement on behalf of the parties for whom they are signing.

16. The parties hereto each agree not to disclose the

contents of this executed Agreement.

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IN WITNESS WHEREOF, the parties hereto have entered into

and executed this Agreement, on the date opposite their names.

 

Dated: 9 Apr 87

[signed] Vicki Aznaran
VICKI AZNARAN

Dated: 13 April 1987

RELIGIOUS TECHNOLOGY
CENTER

By: [signed] [Warren McShane?]

 

Dated: 14 April 1987

CHURCH OF SCIENTOLOGY
INTERNATIONAL
By: [signed] [Jonathan Epstein?]

 

Dated: 13 April 1987

CHURCH OF SCIENTOLOGY
CALIFORNIA
By: [signature]

 

Dated: 9 April 1987

CHURCH OF SPIRITUAL
TECHNOLOGY
By: [signed] Lyman D. Spurlock

 

Dated: 13 April 1987

AUTHOR SERVICES, INC.
By: [signed] John Allcock

 

Dated: 13 April 1987

ESTATE OF L. RON HUBBARD
By: [signed] Norman F. Starkey

 

Dated: 13 April 1987

AUTHOR'S FAMILY TRUST
By: Norman F. Starkey

   

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