HUB LAW OFFICES
711 SIR FRANCIS DRAKE BOULEVARD
SAN ANSELMO, CALIFORNIA 94960-1949
LICENSE NO. 107601
FACSIMILE (415) 5318
February 19, 1992
|Laurie J. Bartilson
BOWLES & MOXON
6255 Sunset Boulevard, Suite 2000
Los Angeles, California 90028
B & M 213-662-6419
C & B 818-883-2033
RE: Scientology v. Armstrong
Marin County Superior Court
Case No. 152229
Dear Ms. Bartilson:
The Scientology organization has based its complaint and its
motion for preliminary injunction against Gerald Armstrong in
large part on attorney Lawrence Heller's rendition of the
settlement negotiations and interpretation of the settlement
agreement. We are aware of the fact that Gerald Armstrong's
attorneys, Michael Flynn, Bruce Bunch and Julia Dragojevic are
specifically prohibited from giving a declaration to Armstrong
which would refute Heller's allegations, as well as those of
other organization attorneys.
We therefore request that you release each of Gerald
Armstrong's former attorneys from such prohibition so that they
can provide him with declarations and assist him in the above-
referenced litigation. If we do not receive notice of such
release by February 24, 1992, we will ask the Court for a ruling
that Heller's and the organization's allegations concerning the
settlement agreement are false and that they be stricken.
cc: Gerald Armstrong
Michael J. Flynn, Esq.
Bruce Bunch, Esq.
Julia Dragojevic, Esq.
Andrew H. Wilson, Esq.