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FORD GREENE
LAWYER

HUB LAW OFFICES
711 SIR FRANCIS DRAKE BOULEVARD
SAN ANSELMO, CALIFORNIA 94960-1949
(415) 258-0360

LICENSE NO. 107601
FACSIMILE (415) 5318

February 24, 1992

 

LAURIE J. BARTILSON, ESQ.
Bowles & Moxon
6255 Sunset Boulevard, Suite 2000
Los Angeles, California 90028

By Telecopier

RE: Scientology v. Armstrong
Marin County Superior Court
Case No. 152229


Dear Ms. Bartilson:

    In its motion for preliminary injunction for breach of
contract, the Scientology organization cites to and relies on
Wakefield v. Church of Scientology of California, claiming that
the Wakefield "settlement agreement contain[s] terms
substantially similar to those which Armstrong has violated
here." The organization moreover claims that "CSC has already
successfully obtained injunctions and specific performance of
settlement agreements containing similar provisions."

    Our research has revealed that none of the " well over a
dozen plaintiffs" involved in "the settlement negotiations" (see
Heller declaration) was advised that the agreement was not
reciprocal: i.e., that the organization could say whatever it
wanted about the signing plaintiffs following the settlement but
the signing plaintiffs must remain silent. Our research reveals,
moreover, that signing plaintiffs were advised, as was Mr.
Armstrong, by their attorney, Michael J. Flynn, that the
settlement agreements "are not worth the paper they are printed
on."

     The issues of reciprocality of the settlement conditions and
the advise of the "negotiating" attorney that the agreement
conditions are unenforceable clearly affect the motion for
preliminary injunction, and relate to the good or bad faith in
which the motion has been brought.

     We are aware of the fact that each of the " well over a dozen
plaintiffs" is specifically prohibited from providing Mr.
Armstrong with a declaration regarding the settlement agreement,
its reciprocality, advice of unenforceability, other facts which
would refute Heller's allegations concerning the settlement

 

 

LAURIE J. BARTILSON, ESQ.
February 24, 1992
Page 2.           /

By Telecopier

 

negotiations and results, and from providing Mr. Armstrong with
copies of their "substantially similar" settlement agreements.

    We therefore request that you release each of the plaintiffs
involved in settlements with your organization from such
prohibition so they can provide Mr. Armstrong with declarations
and assist him in his defense of your charges. If we do not
receive notice of such release by February 26, 1992, we will ask
the Court for a ruling that all cites and references to other
" substantially similar" settlement agreements be stricken, that
the Armstrong settlement agreement was reciprocal, that the
organization knew that it was unenforceable, and that Heller's
representations to the contrary are false and that they be
stricken.

Sincerely,

[signed]
FORD GREENE

:acg

cc: Gerald Armstrong
Andrew H. Wilson, Esq.
Michael J. Flynn, Esq.
Julia Dragojevic, Esq.
Bruce Bunch, Esq.
Garry P. McMurry, Esq.
Walt Logan, Esq.
Nancy Dincalci
Kima Douglas
Michael Douglas
Robert Dardano
Warren Friske
William Franks
Laurel Sullivan
Edward Walters
Howard Schomer
Martin Samuels
Julie Christopherson
Nancy McLean
John McLean
Tonja Burden
Gabe Cazares
Margery Wakefield

 

 
 

This document in .pdf format.

 

 

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