CT 6288]

JOHN G. PETERSON
PETERSON AND BRYAN
8530 Wilshire Boulevard, Suite 407
Beverly Hills, California 90211
(213) 659-9965
Attorneys for Plaintiff and Cross-Defendant
CHURCH OF SCIENTOLOGY OF CALIFORNIA

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

CHURCH OF SCIENTOLOGY OF CALIFORNIA, a California Corporation, Plaintiff, v. GERALD ARMSTRONG, et al., Defendants. AND RELATED CROSS-ACTION.

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CASE NO. C 420 153 CROSS-DEFENDANT CHURCH OF SCIENTOLOGY OF CALIFORNIA’S RESPONSE TO CROSS-COMPLAINANT GERALD ARMSTRONG’S REQUEST FOR PRODUCTION OF DOCUMENTS

Cross-Defendant Church of Scientology of California responds to Cross-Complainant’s Request for Production of Documents as follows:

1. without waiving any objections, Cross-Defendant responds that, to the extent said documents pertaining to Cross-Complainant exist, they have already been produced.

2. Cross-Defendant will produce the documents in its possession, custody or control.

3. Cross-Defendant has no such documents in its possession, custody or control.

4. Without waiving any objections, Cross-Defendant

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responds that it has no such documents in its possession, custody or control.

5. Without waiving any objections, Cross-Defendant responds that to the extent that any documents exist within this category, said documents have already been produced.

6. Cross-Defendant has no such documents in its possession, custody or control.

7. Without waiving any objections, Cross-Defendant responds that to the extent that any documents exist within this category, said documents have already been produced.

8. Cross-Defendant has no documents which show any alleged assault of Cross-Complainant, running into him, or any attempts to involve Cross-Complainant and Joyce Armstrong in freeway accidents or any type of harassment. Correspondence and reports to and from private investigators are privileged as attorney work product.

9. Cross-Defendant has no such documents in its possession, custody or control.

10. Cross-Defendant has no such documents in its possession, custody or control.

11. Cross-Defendant denies that Cross-Complainant was harassed in London in June 1984. Cross-Defendant is aware that Cross-Complainant was legitimately served with a valid order by the California Court of Appeal, and will produce documents in our possession, custody or control.

12. Cross-Defendant has no such documents in its possession, custody or control.

13. Without waiving any objections, no such orders,

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reports or correspondence exist regarding Cross-Complainant. As to documents, any that fall within this Request for Production which pertain to Cross-Complainant either have already been produced or are equally available to Cross-Complainant.

14. Cross-Defendant is searching its files and will produce any of the requested documents in its possession, custody or control.

15. Cross-Defendant has no knowledge of any burglary of Cross-Complainant’s trunk. Hence, Cross-Defendant has no such documents in its possession, custody or control.

16. Cross-Defendant has no such documents in its possession, custody or control.

17. Cross-Defendant has no such documents in its possession, custody or control.

18. Without waiving any objections, Cross-Defendant denies that it has ever obtained any “false authorizations” with respect to any alleged wiretapping of either Cross-Complainant or Michael Flynn. No documents exist.

19. Cross-Defendant has no such documents in its possession, custody or control.

20. Cross-Defendant has no such documents in its possession, custody or control.

21. “Armstrong Operation” is a characterization invented by Cross-Complainant as no such “operation” has ever existed.

Cross-Defendant has no such documents in its possession, custody or control.

22. Cross-Defendant has no such documents in its

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possession, custody or control. There is no such thing as an operation to frame Flynn and Armstrong regarding the $2,000,000 check. Object to production of documents regarding check as not leading to discovery of admissible evidence relevant to this case.

23. Cross-Defendant objects on the grounds that this Request is vague, ambiguous, overbroad, burdensome and harassive. The documents requested herein are irrelevant to any cause of action in the cross-complaint and are not calculated to lead to the discovery of any evidence admissible in this action.

24. Cross-Defendant incorporates by reference as if fully set forth herein its response to Request for Production No. 23.

25. This Request for Production seeks documents which, in part, are irrelevant to any cause of action in the cross-complaint and are not calculated to lead to the discovery of any evidence admissible in this action. Any documents which are calculated to lead to the discovery of admissible evidence and which do exist have already been produced to Cross-Complainant.

26. See response to Request #25.

27. Any such documents which exist have already been produced to Cross-Complainant.

28. Any such documents which exist have already been produced to Cross-Complainant.

29. Cross-Defendant has no such correspondence, orders, reports, statements, payments, reports or cancelled checks in its possession, custody or control. Cross-Defendant possesses

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a declaration of L. Pletcher Prouty which will be produced.

30. Cross-Defendant will produce the requested videotape in its possession, custody or control.

31. Cross-Defendant is informed and believes that Cross-Complainant already has complete copies of the videotapes requested herein. No other documents exist. Nothing, either audio or visual, was edited from said videotapes. There are no correspondence, orders, reports, statements, documents or materials relating to an editing prior to Christofferson.

32. Cross-Defendant has no such documents in its possession, custody or control.

33. Cross-Defendant cannot locate any specific items that have been sent to the media, however, a continued search is being made to ascertain if items sent to media on other subjects contained information regarding Cross-Complainant. Cross-Defendant will supplement this response if any are
located.

34. Cross-Defendant has no such documents in its possession, custody or control.

35. Cross-Defendant has no such documents in its possession, custody or control.

36. Cross-Defendant has no such documents in its possession, custody or control.

37. Cross-Defendant will produce all documents and materials in our possession except memo to files dated 10-21-85, 11-19-85 and 11-20-85, from attorney Roger Geller which is privileged as attorney work product.

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Cross-Defendant has no such documents in its possession, custody or control.

39. This Request for Production seeks documents which are irrelevant to any cause of action in the cross-complaint and is not calculated to lead to the discovery of any evidence admissible in this action.

40. Cross-Defendant has no such documents in its possession, custody or control.

41. Without waiving any objections, Cross-Defendant denies that any “operation or mission” to “‘Black PR” Cross-Complainant” ever existed. Cross-Defendant has no such documents in its possession, custody or control.

42. Cross-Defendant has no such documents in its possession, custody or control.

43. Cross-Defendant has no such documents in its possession, custody or control.

DATED: September 2, 1986

PETERSON & BRYNAN
BY: [signed]
JOHN G. PETERSON