Declaration of Andrew H. Wilson In Support Of Motion To Attach An Order For Issuance of Writ Of Attachment After Hearing

Armstrong 4

ANDREW H. WILSON, ESQ., SBN 063209
LINDA M. FONG, ESQ., SBN 124232
WILSON CAMPILONGO LLP
115 Sansome Street, Suite 400
San Francisco, California 94104
(415) 391-3900
(415) 954-0938 (fax)

KENDRICK MOXON, ESQ., SBN 128240
MOXON & BARTILSON
6255 Sunset Boulevard, Suite 2000
Hollywood, CA 90028
(213) 953-3360
(213) 953-3351 (fax)

Attorneys for Plaintiff/Judgment Creditor

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF MARIN

CHURCH OF SCIENTOLOGY
INTERNATIONAL, a California not-for-profit
religious corporation;

Plaintiff,

vs.

GERALD ARMSTRONG, et al.,

Defendants.

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)		 Case No. 157 680

[CONSOLIDATED]

DECLARATION OF ANDREW H.
WILSON IN SUPPORT OF
MOTION FOR RIGHT TO
ATTACH AN ORDER FOR
ISSUANCE OF WRIT OF
ATTACHMENT AFTER
HEARING

Date: June 6, 1997
Time: 9:00 a. m.
Place: Dept 1, Courtroom H

I, ANDREW H. WILSON, declare as follows:

1. I am a partner of the law firm of Wilson Campilongo LLP and am an attorney admitted to practice in the State of California. I am one of the attorneys responsible for the representation of the Plaintiff/Judgment Creditor in this action. As such, I have personal knowledge of the facts set forth below and, if called upon to testify on such matters, would and could do so competently.

2. Attached hereto and incorporated by reference as Exhibits A through D are true and correct copies of the indicated pages of the depositions of the following persons:

Exhibit A - Deposition of Michael Walton taken February 24, 1993 at pp. 27 and 39; Deposition of Michael Walton taken March 18, 1994 at pp. 28, 42, 48-49 and 78-79.

Exhibit B - Deposition of Solina Walton taken January 26, 1995 at pp. 13, 19, 23, 28, 50, 60, 80, 82 and 91.

Exhibit C - Deposition of Gerald Armstrong taken June 24, 1992 at pp. 83-87, 102-103, 123-124, 151, 163-164 and 173-174; Deposition of Gerald Armstrong taken July 22, 1992 at pp. 267 and 269; Deposition of Gerald Armstrong taken March 17, 1994 at pp. 73, 79 and 95.

Exhibit D - Deposition of Michael Douglas taken August 30, 1994, at pp. 21 and 22.

3. I am informed and believe that on or about April 16, 1997, the residence which is the subject of this action, a residence located on Fawn Drive, San Anselmo, California was destroyed by fire. Attached hereto and incorporated by reference as Exhibit E is a copy of an article from the Marin Independent Journal describing that fire.

I declare under penalty pursuant to the laws of the State of California that the foregoing is true and correct. Executed this 13th day of May 1997 at San Francisco, California.

 

[signed Andrew H. Wilson]

ANDREW H. WILSON

ANDREW H. WILSON, ESQ., SBN 063209
LINDA M. FONG, ESQ., SBN 124232
WILSON CAMPILONGO LLP
115 Sansome Street, Suite 400
San Francisco, California 94104
(415) 391-3900
(415) 954-0938 (fax)

KENDRICK MOXON, ESQ., SBN 128240
MOXON & BARTILSON
6255 Sunset Boulevard, Suite 2000
Hollywood, CA 90028
(213) 953-3360
(213) 953-3351 (fax)

Attorneys for Plaintiff/Judgment Creditor

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF MARIN

CHURCH OF SCIENTOLOGY INTERNATIONAL, a California not-for-profit religious corporation;

Plaintiff,

vs.

GERALD ARMSTRONG, et al.,

Defendants.

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 Case No. 157 680

[CONSOLIDATED]

PROOF OF SERVICE

Date: June 6, 1997
Time: 9:00 a. m.
Place: Dept 1, Courtroom H

PROOF OF SERVICE

I declare that I am employed in the City and County of San Francisco, California.

I am over the age of eighteen years and not a party to the within entitled action. My business address is 115 Sansome Street, Suite 400, San Francisco, California.

I am readily familiar with Wilson Campilongo LLP's practice for collection and processing of correspondence by mailing with the United States Postal Service.

On May 13, 1997, I caused the attached copy of NOTICE OF APPLICATION AND HEARING FOR RIGHT TO ATTACH ORDER; ORDER FOR ISSUANCE OF WRIT OF ATTACHMENT; APPLICATION FOR RIGHT TO ATTACH ORDER; ORDER FOR ISSUANCE OF WRIT OF ATTACHMENT AFTER HEARING; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF APPLICATION FOR RIGHT TO ATTACH AN ORDER FOR ISSUANCE OF WRIT OF ATTACHMENT AFTER HEARING; and DECLARATION OF ANDREW H. WILSON IN SUPPORT OF MOTION FOR RIGHT TO ATTACH AN ORDER FOR ISSUANCE OF WRIT OF ATTACHMENT AFTER HEARING on the following in said cause, by placing for deposit with the United States Postal Service on this day in the ordinary course of business, true copies thereof enclosed in sealed envelopes. The envelopes were addressed as follows:

Gerald Armstrong
715 Sir Francis Drake Blvd.
San Anselmo, California 94960

Michael Walton
700 Larkspur Landing Circle, #120
Larkspur, CA 94939

I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed at San Francisco, California on May 13, 1997.

 

[signed Colleen Y. Palmer]

Colleen Y. Palmer