Declaration Of Andrew H. Wilson In Support Of Motion For Summary Judgment

CSI v. Gerald Armstrong, Robert Minton, Lisa McPherson Trust

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ANDREW H. WILSON, SBN 63209
WILSON CAMPILONGO LLP
475 Gate Five Road, Suite 212
Sausalito, CA 94965-1475
Telephone: (415) 289-7100
Facsimile: (415) 289-7110

Attorney for Plaintiff
CHURCH OF SCIENTOLOGY INTERNATIONAL

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF MARIN

CHURCH OF SCIENTOLOGY INTERNATIONAL, a California nonprofit
religious corporation,

Plaintiff,

vs.
GERALD ARMSTRONG, an individual;
and DOES 1 THROUGH 50, inclusive,

Defendants.


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CASE NO. CV 021632

DECLARATION OF ANDREW H. WILSON IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT FILED CONCURRENTLY HEREWITH

Date: February 3, 2004
Time: 9:00 a.m.
Dept: L

Complaint Filed: April 2, 2002
Trial Date: March 5, 2004

Andrew H. Wilson deposes and says:

1. My name is Andrew H. Wilson. I am the attorney of record representing the Plaintiff in the instant action. I have personal knowledge of the documents and underlying facts surrounding said documents as stated herein and could competently testify thereto if called as a witness herein.

2. Attached hereto and incorporated herein as Exhibit A is a true and correct copy of the Mutual Release of All Claims and Settlement Agreement between Church of Scientology International ("CSI") and Gerald Armstrong ("Armstrong") in the case Gerald Armstrong v. Church of Scientology of California, Los Angeles Superior Court, Case No. 420 153, executed in December of 1986, accompanied by an affidavit executed by Armstrong and notarized on

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December 6, 1986.

3. Attached hereto and incorporated herein as Exhibit B is a true and correct copy of the Answer of Gerry Armstrong in the instant case, dated November 5, 2002.

4. Attached hereto and incorporated herein as Exhibit C is a true and correct copy of Verified Complaint for Damages and for a Preliminary and Permanent Injunction for Breach of Contract in the matter entitled Church of Scientology International vs. Gerald Armstrong., Marin Superior Court, Case No. 152229, filed on February 4, 1992.

5. Attached hereto and incorporated herein as Exhibit D is a true and correct copy of Verified Complaint to Set Aside Fraudulent Transfers and for Damages; Conspiracy in the matter entitled, Church of Scientology International vs. Gerald Armstrong, Michael Walton, etc., Marin Superior Court, Case No.157680 filed on July 23, 1993.

6. Attached hereto and incorporated herein as Exhibit E is a true and correct copy of a Verified Cross-Complaint related to the matter entitled Church of Scientology International vs.Gerald Armstrong, Michael Walton, etc., Marin Superior Court, Case No. 157680.

7. Attached hereto and incorporated herein as Exhibit F is a true and correct copy of an Order of Permanent Injunction granted by the Honorable Gary W. Thomas on October 17, 1995 in the matter entitled Church of Scientology International vs. Gerald Armstrong, Michael Walton, etc., Marin Superior Court, Case No. 157680.

8. Attached hereto and incorporated herein as Exhibit G is a true and correct copy of the Consolidated Judgment in the matter entitled Church of Scientology International vs. Gerald Armstrong, Michael Walton, etc., Marin Superior Court, Case No. 157680.

9. Attached hereto and incorporated herein as Exhibit H is a true and correct copy of an Ex Parte Application for an Order to Show Cause re: Contempt and supporting documents which include the Memorandum of Points and Authorities and Declaration of Andrew H. Wilson in a matter entitled Church of Scientology International v. Gerald Armstrong, Marin Superior Court, Case No. 152229.

10. Attached hereto and incorporated herein as Exhibit I is a true and correct copy of the Opposition to Order to Show Cause re: Contempt and the Declaration of Gerald Armstrong in

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the matter entitled Church of Scientology International v. Gerald Armstrong, Marin Superior Court, Case No. 152229.

11. Attached hereto and incorporated herein as Exhibit J is a true and correct copy of the Order of Contempt issued by the Honorable Vernon F. Smith of the Marin Superior Court in the matter entitled Church of Scientology International v. Gerald Armstrong, Marin Superior Court, Case No. 152229.

Dated: November 17, 2003

Respectfully submitted:

WILSON CAMPILONGO LLP

By: [signed] Andrew H. Wilson

Andrew H. Wilson

Attorneys for Plaintiff
CHURCH OF SCIENTOLOGY
INTERNATIONAL