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ANDREW H. WILSON

WILSON CAMPILONGO LLP
115 SANSOME STREET, SUITE 400
SAN FRANCISCO, CALIFORNIA 94104
(415) 391-3900
TELECOPY (415) 954-0938

 

February 25, 1997

[stamp]
RECEIVED
FEB 27 1997
GEORGE W. ABBOTT

George Abbott, Esq.
2245-B Meridian Blvd.
P.O. Box 98
Minden, Nevada 89423-0098

Re: Church of Scientology v. Armstrong
Our File No. SCI02-003

Dear Mr. Abbott:

     This firm represents the Church of Scientology International ("CSI") in the referenced matter
and has been asked to respond to your letter dated, curiously, "February 12th and 14th, 1997."

     Although you say that you conducted a " reasonable inquiry" that the allegations you made
are grounded in fact, it is quite apparent that your are ignorant of the lengthy history of the dispute
between my client and Mr. Armstrong. Although you allude to it, you are unaware or have ignored
the import and effect of the settlement agreement (the "Agreement") which they entered into on
December 8, 1986. As you should know from your reasonable investigation, Mr. Armstrong raised
every conceivable challenge to the Agreement in the referenced action, including the argument that
the Agreement could not prohibit him from responding to allegations made by CSI concerning him.

     All of Mr. Armstrong's arguments were rejected each time he made them. Armstrong was
first enjoined from violations of the Agreement by the Hon. Michael Dufficy in March of 1992 by
way of a temporary restraining order. The Hon. Ronald Sohigian in May, 1992, entered a
preliminary injunction to similar effect. Judge Sohigian's order was appealed by Armstrong and
affirmed in an opinion which dismissed Armstrong's arguments out of hand. In January of 1996,
a Judgement of Permanent Injunction (the "Injunction") was entered against Armstrong in Marin
County Superior Court following an order entered by the Hon. Gary Thomas summarily adjudicating
various causes of action, including one for injunctive relief . It would behoove you to review these
orders, and the papers in support and in opposition to the motions which resulted in those orders
before advising Mr. Armstrong that "...he is free to communicate orally, in writing or by any other
legal means available to him to fully correct..." alleged lies and distortions. The fact is that Mr.
Armstrong is not free to do that. Mr. Armstrong's sole remedy is to seek appropriate relief for
alleged defamatory statements.

     The problem, of course, with that approach is that Mr. Armstrong will never be able to prove
defamation. I have reviewed the documents which you allege are defamatory and am unable to find
any statement concerning Mr. Armstrong, much less one which is defamatory. Please enlighten me

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as to which statements you contend are defamatory, and why you make that contention. Please also
inform me exactly how Mr. Armstrong became aware of the alleged defamatory communication and
what persons Mr. Armstrong believes he needs to communicate with in order to correct these alleged
defamatory statements.

     Your letter refers to Mr. Armstrong as your "friend and neighbor." It is my understanding
that Mr. Armstrong currently resides in San Anselmo, California. In fact, I gave Mr. Armstrong
notice on Friday, February 14 by telephone to his residence in San Anselmo (Telephone No. 456-
8450) of an ex parte application for the issuance of an order to show cause re contempt. The
telephone was answered by an answering machine which played a recording of the voice of Lorien
Phippany which stated "Please leave a message for either Jerry or Lorien." As I was drafting this
letter, I again called that number and heard exactly the same message. If Mr. Armstrong is currently
residing in Minden, Nevada or its environs, I would appreciate your letting me know.

     For your information, the ex parte application was successful. I enclose the application,
supporting papers, and the order to show cause which Judge Thomas issued. You should find it
interesting reading. I believe that my client has shown remarkable restraint in its dealing with Mr.
Armstrong in enforcing the Judgment. It is apparent that Mr. Armstrong has a pathological inability
to remain disconnected from CSI. This inability manifests itself in various provocations, such as the
letter to the Los Angeles City Council which you must have discovered in the course of your
reasonable investigation. CSI has "turned the other cheek" when it could, given the pathetically
ineffectual nature of most of these provocations. However, it could not sit idly by in the face of Mr.
Armstrong's direct communication with a sitting United States District Judge.

     It is apparent to me that you and Mr. Armstrong are colluding to create a defense to a charge
of contempt against Mr. Armstrong, as evidenced by your statement that you have advised Mr.
Armstrong that he is free to communicate with anyone to correct lies which have been told about
him. Before you provide Mr. Armstrong with such a purported "advice of counsel" defense, you
should carefully consider whether you have a reasonable basis for such advice, whether you are
subjecting yourself to liability for your uninformed advice or, even worse, for your collusion with
Armstrong to avoid the Court's directive, and whether you are ultimately willing to be yet another
victim of Mr. Armstrong's pathology.

 

Very truly yours,

WILSON CAMPILONGO LLP

[signed Andrew H. Wilson]

Andrew H. Wilson

AHW-1917.ltr
Enclosures

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