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TIMOTHY BOWLES
ALSO ADMITTED OREGON
KENDRICK L. MOXON
ALSO ADMITTED WASH DC
LAURIE J. BARTILSON
ALSO ADMITTED MASSACHUSETTS
BOWLES & MOXON
ATTORNEYS AT LAW
6255 SUNSET BOULEVARD
SUITE 2000
——
HOLLYWOOD, CALIFORNIA 90028
(213) 661-4030
TELECOPIER (213) 662-6419

HELENA M. KOBRIN
ALSO ADMITTED FLORIDA
WILLIAM D KATZ
——
OF COUNSEL
JEANNE M. CAVIGAN
MARCELLO M. DI MAURO
KAREN L. BROWN
——

March 2, 1992

BY TELEFAX AND U.S. MAIL

 

Ford Greene
Hub Law Offices
711 Sir Francis Drake Boulevard
San Anselmo, California 94960-1949

RE: Church of Scientology International v. Armstrong

Dear Mr. Greene:

     I have received your letters of February 19 and 24
concerning the above?entitled matter, which purport
simultaneously to acknowledge the validity and binding nature of
the settlement agreement at issue in this case, and to disregard
its provisions in the service of your client, Mr. Armstrong.
Your letter of February 24, with its boast of "research" and
mailings to others who peacefully settled their actions with CSI
long ago, demonstrates dramatically the need for the requested
preliminary injunction to issue forthwith.

     In 1986, your client, represented by counsel, entered into a
detailed, written and explicit settlement agreement. He
initialed each page of the agreement, and signed the final page,
as did his lawyer. If your comments are to be taken as true that
Mr. Armstrong, at the time that he signed the agreement with CSI,
in fact believed that the agreement was "not worth the paper that
[it was] printed on," then he obviously and in fact perpetrated a
serious fraud on CSI in an attempt to induce CSI to pay him money
in exchange for a settlement which he had no intention of
honoring. You can rest assured that this fraud will be properly
dealt with by CSI and the courts, along with any additional
violations of the terms of the settlement agreement either by Mr.
Armstrong,or by you as his agent.

     If it is your claim that Mr. Flynn fraudulently induced your
client into both signing a settlement agreement under false
pretenses and defrauding CSI into paying him settlement funds,
then that is a claim which Mr. Armstrong must make, if at all,
against Mr. Flynn. Such an allegation does not negate Mr.
Armstrong's contractual responsibilities vis a vis CSI, nor does
it excuse Mr. Armstrong's breaches, particularly given the

 

Ford Greene
March 2, 1992
Page Two

specific nature of the representations made by Mr. Armstrong on
videotape at the time that he signed the contract.

     I would also note in response to your letters that CSI does
indeed rely on Wakefield v. Church of Scientology for the
reported precedent which it sets. I must admit, however, that I
find your interest in diverting the court's attention to the
facts of that case puzzling indeed. As Ms. Wakefield's former
counsel, you no doubt recall that, after the first day of the in
camera
proceedings, you appeared in court without your client,
and announced that she had checked into a hospital because she
was feeling suicidal. Your request for adjournment at that time
was naturally granted. Later, however, your client appeared
before the court and sought to have you removed as her counsel,
claiming, in a sworn affidavit, that you had failed to prepare
any witnesses to appear at the hearings on Ms. Wakefield's
behalf: attempted to incarcerate her in a mental hospital against
her will; engaged her in long, personal phone calls very late at
night or early in the morning: attempted to have a sexual
relationship with her: and generally acted "without competence"
in your handling of her case. I understand that when you were
informed of the affidavit and its contents, you asked leave to
withdraw from the case, and leave was promptly granted by the
court. If you feel that these facts are somehow relevant to Mr.
Armstrong's defense, you are welcome to raise them with the
court.

     Finally, it is apparent from your letters that Mr. Armstrong
has acknowledged that he signed the agreement, considers it
binding, and has willfully breached its terms. In light of this,
we request that Mr. Armstrong agree to the entry of the
preliminary injunction as requested for the pendency of this
matter. Please inform me no later than March 3, 1992, whether
Mr. Armstrong will stipulate to the entry of the preliminary
injunction.

Very truly yours,
BOWLES & MOXON
[signed]
Laurie J. Bartilson

LJB:mfh
cc: Andrew Wilson

 

 
 

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