COOLEY GODWARD LLP BENJAMIN K. RILEY (112007) NICOLE A. SIMON (216087) One Maritime Plaza, 20th Floor San Francisco, CA 94111-3580 Telephone: (415) 693-2000 Facsimile: (415) 951-3699 Attorneys for Defendants ROBERT MINTON and THE LISA MCPHERSON TRUST

[stamped] FILED AUG 21 2002 JOHN P. MONTGOMERY Court Executive Office MARIN COUNTY SUPREME COURT By N. Johnson, Deputy

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF MARIN

CHURCH OF SCIENTOLOGY INTERNATIONAL, a California nonprofit religious corporation, Plaintiff, vs. GERALD ARMSTRONG, an individual; ROBERT MINTON, an individual; THE LISA McPHERSON TRUST, a for-profit corporation; and DOES 1 THROUGH 50, inclusive, Defendants.

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CASE NO. CV 021632 DEFENDANT ROBERT MINTON AND THE LISA MCPHERSON TRUST'S ANSWER TO PLAINTIFF'S COMPLAINT FOR DAMAGES

Defendants Robert Minton and The Lisa McPherson Trust ("Defendants") hereby answer the unverified allegations of the Complaint for Damages for Breach of Contract, Intentional Interference with Contractual Relations, and Conspiracy to Breach Contract and to Interfere With Contractual Relations ("Complaint"), filed herein on or about April 2, 2002 by plaintiff Church of Scientology International ("Scientology"), by denying generally each and every allegation contained therein pursuant to California Code of Civil Procedure section 431.30.

AFFIRMATIVE DEFENSES

As for their affirmative defenses, Defendants are informed and believe and thereupon allege as follows:

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1. The Complaint and each cause of action alleged against Defendants therein fail to state facts sufficient to constitute a cause of action against Defendants.

2. The Complaint and each cause of action alleged against Defendants therein is barred by reason of the terms of the Settlement Agreement.

3. The Complaint and each cause of action alleged against Defendants therein is barred by reason of the applicable statute of limitations, including, without limitation, Code of Civil Procedure section 339.

4. Scientology knew, should have known and/or was fully advised concerning the matters alleged in the Complaint, and thus Scientology is precluded from asserting any such claims against Defendants.

5. Scientology has not been damaged as a result of the conduct of Defendants, and/or any actual damage was incurred by reason of Scientology's own conduct, decision and/or choice.

6. Scientology failed to mitigate or minimize its alleged damages, if any, and is therefore barred from recovering damages which could have been prevented.

7. Scientology is precluded and barred from asserting any claim against or recovering any damages from Defendants arising out of any of the matters alleged to have occurred in the Complaint by virtue of the doctrine of laches.

8. Scientology is precluded and barred from asserting any claim against or recovering any damages from Defendants arising out of any of the matters alleged to have occurred in the Complaint by virtue of the doctrine of estoppel.

9. Scientology is precluded and barred from asserting any claim against or recovering any damages from Defendants arising out of any of the matters alleged to have occurred in the Complaint by virtue of the doctrine of waiver.

10. Scientology is precluded and barred from asserting any claim against or recovering any damages from Defendants arising out of any of the matters alleged to have occurred in the Complaint by virtue of the doctrine of unclean hands.

11. Defendants were justified and/or privileged in doing any and all of the acts alleged in the Complaint.

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PRAYER

WHEREFORE, Defendants pray that a final judgment be entered in their favor and against Scientology on the Complaint such that Scientology receives nothing and Defendants receive their costs and all other relief this Court deems just and proper.

Dated: August 20, 2002

COOLEY GODWARD LLP By: [signed] Benjamin K. Riley Attorneys for Defendants ROBERT MINTON and THE LISA MCPHERSON TRUST