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SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

I, LAURIE J. BARTILSON, hereby declare:

1. I am a partner in the law firm of Bowles & Moxon and am an attorney admitted to practice in the State of California. My firm represents plaintiff Church of Scientology International ("Church") in the instant case. I am submitting this declaration in support of the Church's Second Ex Parte Application for Order

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to Show Cause Why Gerald Armstrong Should Not Be Held in Contempt ("Application"). I have personal knowledge of the matters specified in this declaration and, if called upon to testify on such matters, would and could do so competently.

2. In the Church's December 31, 1992 ex parte application for order to show cause in this case and in my supporting declaration to that application and accompanying exhibits, the Church documented at least six earlier instances of Armstrong's wilful violations of the May 28, 1992 preliminary injunction order of this Court ("May 28 order"). As required, my December 31, 1992 declaration ("First Dec.") contained allegations of: (a) the issuance of the May 28 order ( First Dec., ¶ 2): (b) notice to Armstrong of the May 28 order through notice to his attorneys on June 5, 1992 in the manner authorized by the Court (First Dec., ¶

3): (c) Armstrong's knowledge of the May 28 order through his statements that he was aware of but would never comply with such order (First Dec., ¶¶ 4, 5, 9, 10 and 13); and (d) Armstrong's ability to have complied with such order (through his actions of assistance to anti-Church litigants, including his latest instance specified in paragraph 5 below, Armstrong was just as able to desist from such actions ( First Dec., ¶¶ 4, 5, 9, 11, 12 and 13)). My December 31, 1992 declaration is attached as Exhibit 1 hereto and its statements and allegations are incorporated by reference into this declaration.

3. The May 28 order states, in part:

Defendant Gerald Armstrong ... and persons acting in concert ... with him ... are restrained and enjoined
during the pendency of this suit pending further order of this court from ... [v]oluntarily assisting any person ... litigating a claim against the persons

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referred to in sec. 1 of the " Mutual Release of All Claims and Settlement Agreement " of December 1986. Exhibit A to Application, May 28 order, p. 2, ¶ 6. The persons and entities protected by the prohibition against voluntary assistance include plaintiff Church and the Church of Scientology of California. Exhibit B to Application, Mutual Release of All Claims and Settlement Agreement, p. 1, ¶ 1.

4. Less than a month after the May 28 order was issued, Armstrong asserted under oath in deposition that he would not honor its terms.

I have absolutely no intention of honoring that settlement agreement. I cannot. I cannot logically. I cannot ethically. I cannot morally. I cannot psychically. I cannot philosophically. I cannot spiritually. I cannot in any way. And it is firmly my intention not to honor it.

Q. No matter what the court says?

A. No court can order it. They're going to have to kill me.

Exhibit C to Application, June 24, 1992 deposition of Gerald Armstrong, p. 124. Armstrong also stated his intent to ignore the May 28 order in a December 22, 1992 letter to plaintiff's counsel. Exhibit D to Application.

5. Larry Wollersheim is a former Church member who has been actively pursuing claims against the Church of Scientology of California in litigation since 1980. On or about June 17, 1993, I received a set of exhibits in support of Larry Wollersheim's motion to strike in Church of Scientology of California v.Wollersheim, Los Angeles County Superior Court No. 074815. I represent the Church of Scientology of California in that case. Designated as exhibit 6 in that set was a copy of a five-page

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declaration of Gerald Armstrong, showing on the last page that Armstrong had executed the document under oath on June 4, 1993. That declaration contained an Armstrong diatribe against the Churches of Scientology. Exhibit J to Application.

6. I allege that execution and delivery of the June 4, 1993 declaration by Armstrong to Wollersheim and/or Wollersheim's counsel is a violation of the prohibition in the May 28 order against voluntary assistance to Church adversaries in litigation and is in deliberate contempt of this Court's authority.

7. On July 23, 1993, I gave notice of this application to Armstrong's counsel, Ford Greene and Paul Morantz, by telefax communication. A true and correct copy of my letter giving notice is attached hereto as Exhibit 2, together with telefax transmission confirmation sheets. I received a response to my letter from defendant Armstrong, Exhibit 3, and responded to that communication on July 23, 1993, Exhibit 4.

Neither Armstrong nor his counsel indicated whether or not they intended to oppose this application.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed on this 24th day of July, 1993 at Los Angeles, California.

H:\ARMSTRON\LAURIE.DEC

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