I, GERALD ARMSTRONG, declare and state that:

1. I have made a previous declaration in this matter and reiterate that I was a member of Scientology from 1969 to 1981 and involved in litigation with various Scientology entities hereinafter referred to as "the Organization" since 1982 to the present. I am familiar with many of the witnesses, and attorneys and victims who have been involved with various Scientology litigations and I have previously met and recognize the voice of Barry Van Sickle.

2. In the afternoon of July 16, 1991, I was present at the Law Offices of Joseph A. Yanny when Mr. Yanny received a telephone call from Mr. Barry Van Sickle which phone call was placed upon the speaker phone. I heard the conversation between Mr. Van Sickle and Mr. Yanny at that time and in its entirety. During the course of the conversation, Mr. Van Sickle recounted a conversation that he had had with Messrs. Quinn and Drescher regarding settlement of litigation between Bent Corydon and the organization. Mr. Van Sickle stated that he had attended a number of such meetings at which settlement was discussed and that, at one particular meeting, a settlement document was transferred by Mr. Drescher to Mr. Van Sickle with respect to the Corydon litigation.

3. Mr. Van Sickle stated that, during the course of the aforementioned meeting, Messrs. Quinn and Drescher had stated that the objective of the settlement was to make peace. Mr. Van Sickle stated that Mr. Drescher stated, while handing over the settlement agreement, that he realized that the settlement agreement, as proposed, was harsh in its terms. Mr. Van Sickle

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stated further that Mr. Drescher indicated that while he realized it was unethical to suggest such a thing, it was the desire of his clients to have Mr. Van Sickle and Ms. Toby Plevin out of the Scientology litigation business.

I declare under the penalty of perjury under the laws of the United States and the State of California that the foregoing is true and correct and based on my personal knowledge, except those matters stated on information and belief, and as to those matters, I am informed and believe them to be true.

Executed this 16th day of July, 1991 at Los Angeles, California.

[signed]
GERALD ARMSTRONG

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