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

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

DECLARATION OF KENDRICK L. MOXON

I, Kendrick L. Moxon, hereby declare and state:

1. I am an attorney licensed to practice law in the State

of California and the District of Columbia. I make the instant

declaration of my own personal knowledge, and if called to

testify thereto, I could and would do so competently.

2. I have spoken to Joseph Yanny hundreds of times since

1986 when I first met him, and have worked with him on several

legal matters. I was counsel of record for the plaintiffs in

the case of Religious Technology Center, et al. v. Yanny,

et al., L.A.S.C. No. C690211.

3. I am also counsel of record for plaintiff in the case

of Church of Scientology of California v. Gerald Armstrong,

L.A.S.C. No. C420153. I have seen Armstrong in court four or

five times over the past few years.

4. On July 15, 1991, I was at the clerk's office in the

United States District Court for the Central District of

California. While there, at approximately 2:30 p.m., I saw

Yanny in the office, and we said hello to each other. A few

minutes later, I saw Yanny and Armstrong standing together in a

corridor of the clerk's office, between the area of the filing

windows and the files storage space. I walked up to Armstrong,

and said to him, "Does Yanny represent you, too?" Armstrong

nodded his head in assent and at the same time Yanny said "No."

5. I said to Armstrong, "You say yes and Yanny says no."

Yanny interrupted Armstrong's response, and said, "I represent

him only on literary matters." I stated to Armstrong, "Do you

know who I am?" Armstrong said "No." I said, "I'm Rick Moxon,"

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

and held out my hand. He said, "Gerry Armstrong" and shook my

hand. I said to Armstrong, "Scientology literary matters?"

Yanny pulled Armstrong away by the arm, and said, "Talk to his

lawyer."

6. About a minute later, I went into the files area of

the clerk's office, and saw Yanny and Armstrong together

looking at a court file. I went over to them, and asked Yanny

what they were reading. Yanny said "J.J. Gaw v. IRS. Very

interesting. Very interesting." J.J. Gaw is a private

investigator I have retained to conduct investigations on

behalf of the Church of Scientology International. I asked

Yanny if he has sent me service of a paper about which he had

called me last week. He responded and I left the area.

7. Just before 3:00 p.m., I returned to the clerk's

office and spoke to several of the filing window clerks to

verify what file Yanny and Armstrong were reviewing. I

confirmed that with a stack of files in the clerk's area which

was being returned to the shelves after review by a requestor,

was a copy of the Gaw case, No. 91-1906 JSL. I confirmed

this by asking.the clerk to see if the file was present. He

stated that it was and brought the file over to the desk for me

to see.

I declare under penalty of perjury that the foregoing is

true and correct. Signed this 18th day of July 1991, in Los

Angeles, California.

-2-

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