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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

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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

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

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

 
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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
 

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

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