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PLEVIN ATTORNEY AT LAW 2 10700 SANTA MONICA BLVD, SUITE 4-300 LOS ANGELES, CALIFORNIA 90025 3 (213) 788-8660 4 Attorney for Defendant/Cross-Complainant GERALD ARMSTRONG 5 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR AND IN THE COUNTY OF LOS ANGELES 9 CHURCH OF SCIENTOLOGY OF No, C 420 153 10 CALIFORNIA, a California ) Corporation, DECLARATION OF GERALD 11 ) ARMSTRONG IN SUPPORT OF Plaintiff, DEFENDANT AND CROSS- 12 ) COMPLAINANT'S OPPOSITION vs. TO NOTICE OF MOTION AND 13 ) MOTION TO ENFORCE GERALD ARMSTRONG; et al., SETTLEMENT AGREEMENT; FOR 14 ) LIQUIDATED DAMAGES AND TO Defendants. ENJOIN FUTURE VIOLATIONS 15 1~ GERALD ARMSTRONG, CFILED UNDER SEAL1 17 Cross-Complainant, 18 vs. 19 ) Date: December 3, 1991 CHURCH OF SCIENTOLOGY OF Time: 9:00 a.m. 20 CALIFORNIA, a California Dept: 56 corporation, et al., 21 Cross-Defendants. 22 23 I, Gerald Armstrong, declare and state: 24 1. I am making this declaration to support an opposition to 25 a motion brought by the Scientology organization in the case of 26 Church of Scientoloqv of California v. Armstrons, Los Angeles 27 Superior Court No. C420153 to enforce the settlement agreement I 28 had entered into with the organization in December 1986. The -1- \G3\Page.00002 1 facts hereinafter set forth are of my own first-hand knowledge. 2 2. I became involved with Scientology as a customer in 1969 3 in Vancouver, B.C. I worked on staff there in 1970 and in 4 February 1971 joined the Sea Organization (SO or Sea Org) in Los 5 Angeles. I was flown to Spain and joined the Sea Org's flag ship, 6 rrApollo,n in Morocco. L.- Ron Hubbard, the Sea Org's 7 "Commodore,' was on board and operated Scientology internationally 8 through the 'crew' which numbered, during my stay on board of four 9 and a half years, around four hundred. All my staff positions on 10 board involved personal contact with L. Ron Hubbard, Mary Sue 11 Hubbard, administrative organization staff and people in the ports 12 and countries the "Apollo" visited, and included "Ship's 13 Representative' (legal representative), 'Port Captain" (public 14 relations officer), and "Information Officer" (intelligence 15 officer). 16 i 3. In the fall of 1975 after the ship operation moved 17 ashore in Florida I was posted in the Guardian's Office (GO) 18 Intelligence Bureau connected to Hubbard's Personal Office. From 19 December 1975 through June 1976 I held the post of Deputy LRH 20 External Communications Aide, a relay terminal for Hubbard's 21 written and telex traffic to and from Scientology organizations. 22 From July 1976 to December 1977 I was assigned, on Hubbard's 23 ~ order, to the 'Rehabilitation Project Force' (RPF), the SO prison 24 system. In 1978 I worked in Hubbard's cinematography crew in La 25 Quinta, California making movies under his direction until the 26 fall of that year when he again assigned me to the RPF, this time 27 for eight months first in La Quinta, then at a newly purchased 28 base in Gilman Hot Springs near Hemet, California. When I got out of the RPF in the spring of 1979 and until the beginning of 1980 I 1 -2- \G3\Page.00003 1 worked in Hubbard's "Household Unit' (HU) at Gilman, the SO unit 2 which took care of Hubbard's house, personal effects, transport, 3 meals and so forth, as the 'Purchaser,' 'Renovations In-Charge" 4 and "Deputy Commanding Officer HU.' 5 4. Throughout 1980 and until I left the organization in 6 December 1981 I held the organization posts in Hubbard's "Personal 7 Public Relations Bureau' of 'LRH Archivist' and "LRH Personal 8 Researcher,' I assembled in Los Angeles an archive of Hubbard's 9 writings and other materials relating to his history to be used 10 as, inter alia, the basis for a biography to be written about the 11 man. I also worked in Los Angeles for the first few months of 1980 12 on Mission Corporate Category Sortout (MCCS), which had the 13 purpose of restructuring the Scientology enterprise so that 14 Hubbard could continue to control it without being liable for its 15 actions. (A tape recording of two meetings relating to MCCS's 16 actions subsequently became the subject of Church of Scientoloqy 17 of California v. Zolin.) Beginning in the fall of 1980 and 18 continuing until my departure, I provided the biographical 19 writings and other materials, as I collected and organized them, 20 to Omar Garrison, who had contracted with the organization to 21 write the Hubbard biography. I interviewed many people who had 22 known Mr. Hubbard at periods throughout his life, including almost 23 all of his known living relatives. I traveled several thousand 24 miles collecting biographical information and conducting a I 25 genealogy search, and arranged the purchase of a number of 26 collections of Hubbard-related documents and other materials from 27 individual collectors. 28 5. Through my research and study of documentary evidence I was compelled to conclude that Mr. Hubbard had lied about his -3- \G3\Page.00004 1 past, credentials, accomplishments, relationships and intentions. 2 I obtained evidence which disproved many of the claims made by 3 Hubbard in his biographies printed in Scientology publications and 4 used in promotion of the man and his philosophy and psychotherapy; 5 consequently I attempted to get the organization executives 6 responsible for these publ~cations to correct the disproven 7 claims. As a result I was ordered to be security checked, an 8 invasive interrogation employing an electronic meter as a lie 9 detector, a procedure I had undergone many times in the Sea Org. 10 I had by this time obtained evidence which disproved the 11 significant representations Hubbard had made about himself or his 12 'technology' which had drawn me into and kept me in the 13 organization for over twelve years; e.g,, that he was an engineer 14 and an atomic physicist, that he had been crippled and blinded in 15 combat in ww II and had cured himself with his mental science 16 discoveries, that it was a matter of medical record that he had 17 twice been pronounced dead, that his psychotherapy had been 18 subjected to rigorous scientific testing, that it cured all 19 psychosomatic ills and raised IQs a point per hour of therapy (I 20 had by this time had well over a thousand hours), that he had been . 21 remunerated for his labors less than staff members were paid (in 22 my case between $4.30 and $17.20 per week throughout my SO years), 23 and that he and his organization were ethical and well- 24 intentioned. When it became clear to me that I was not going to 25 be able to get the organization or Hubbard to admit to the lies 26 and take a more honest path I, and my wife Jocelyn, left the 27 organization. 28 6. Following my departure the organization published a 'Declaration' dated February 18, 1982 labelling me a 'Suppressive -4- ----~p~~ ----- \G3\Page.00005 1 Person (SP).' An SP is considered in Scientology completely 2 psychotic and destructive, one of the two and a half percent truly 3 evil people on the planet. SPs are viewed as enemies of 4 Scientology and mankind and are targets for the organization's 5 "Fair Game Policy,' which states specifically that they may be 6 lied to, cheated, sued and,destroyed without discipline of the 7 Scientologist committing such acts. The SP Declare also accused 8 me of 'spreading destructive rumors about senior scientologists." 9 I knew in early 1982 that I was the target of Guardian's Office 10 intelligence operations because certain friends were contacted and 11 interrogated about me by known GO intelligence personnel. The 12 organization also appropriated a set of photographs I had 13 entrusted with an associate, Virgil Wilhite, and when I demanded 14 their return told me to get a lawyer. 15 7. A few days later I met with attorney Michael Flynn who 16 agreed to defend me against the organization, which on April 22, 17 1982 published a second SP declare accusing me of eighteen 18 "crimes, high crimes and suppressive acts," including, inter alia, 19 promulgating false information about Hubbard and the organization. 20 In the late spring and summer of 1982 I obtained from Omar 21 Garrison with his permission some of the documents I had delivered 22 to him while in the organization which I considered I would need 23 to defend myself against the organization's charges in the SP 24 declares and whatever actions they would bring against me in the 25 non-Scientology courts. I sent these to Mr. Flynn and to Contos 26 and Bunch, a California law firm which by then had agreed to 27 represent me in scientology litigation. The organization filed 28 suit against me in the Los Angeles Superior Court on August 2, 1982 and the Hubbard biography documents I had sent to my lawyers -5- ~nrrna I ,, \G3\Page.00006 1 were ordered by the Court to be deposited with the clerk where 2 they stayed until trial in the spring of 1984. 3 8, In August and September 1982 the organization employed a 4 number of private investigators to suweil and harass my wife and 5 me. During that period one of these investigators assaulted me 6 bodily, and another struck my body with a car, and attempted to ~J 7 in involve me,a freeway accident by getting in front of my car and 8 slamming on his brakes and pulling alongside my car and swerving 9 into my lane. The organization also attempted to get the Los 10 Angeles Police Department to bring criminal charges against me in 11 connection with the Hubbard documents which had become the subject 12 of the litigation in the Superior Court. 13 9. I filed a cross-complaint in 1982~against various 14 Scientology corporations which was bifurcated from the underlying 15 document case and never tried because it settled in December 1986. 16 The document case was tried without a jury by Judge Paul G. 17 i Breckenridge, Jr. who rendered a decision on June 20, 1984. 18 Between that time and the settlement the organization continued 19 its campaign against me which included at least these acts: 20 * attempted entrapment; 21 , illegal videotaping; 22 filing false criminal charges against me with the Los 23 Angeles District Attorney; 24 * filing false criminal charges against me with the Boston 25 office of the FBI; 26 filing false declarations to bring contempt of court 27 proceedings against me on three occasions; 28 obtaining perjured affidavits from English private investigators, who had harassed me in London in 1984, accusing me -6- \G3\Page.00007 1 of distributing 'sealed' documents; 2 international dissemination of Scientology publications 3 falsely accusing me of crimes, including crimes against humanity; 4 and 5 * culling and disseminating information from my supposedly 6 confidential auditing (psychotherapy) file. 7 10. 'On December 5, 1986 I was flown to Los Angeles, as were 8 several other of Mr. Flynn's clients with claims against the 9 organization to participate in a 'global settlement.' After my 10 arrival in LA I was shown a copy of a document entitled "Mutual 11 Release of All Claims and Settlement Agreement,' hereinafter 12 referred to as 'the settlement agreement,' and some other 13 documents, which I was expected to sign. 14 11. The settlement agreement has now become a public 15 document, and it and its effects are issues in various lawsuits 16 now pending. 17 12. Upon reading the settlement agreement draft I was 18 shocked and heartsick. I told Mr. Flynn that the condition of 19 "strict confidentiality and silence with respect to [myl 20 , experiences with the Corganization]" (settlement agreement, para. 21 7D), since it involved over seventeen years of my life, was 22 impossible. I told him that the 'liquidated damages' clause 23 (para. 7D) was outrageous; that pursuant to the settlement 24 agreement I would have to pay $50,000.00 if I told a doctor or 25 psychologist about my experiences from those years, or if I put on 26 a resume what positions I had held during my organization years. 27 I told Mr. Flynn that the requirements of non-amenability to 28 service of process (para. 7H) and non-cooperation with persons or organizations adverse to the organization (paras. 7G, 10) were -7- A __ __ __~~~_~~~ ~ ~_~_____~__~~_~_ ___ \G3\Page.00008 1 obstructive of justice. I told him that I felt that agreeing to 2 leave the organization's appeal of the decision in Armstrons and 3 not respond to any subsequent appeals (para. 4B) was unfair to the 4 courts and all the people who had been helped by the decision. I 5 told Mr. Flynn that an affidavit the organization was demanding 6 that I sign along with the,settlement agreement was false. That 7 document, which I do not hav.e, stated, inter alia, that my 8 disagreements with the organization had been with prior 9 management, and not with the then-current leadership. In fact 10 there had been no management change and I had the same 11 disagreements with the organization's 'fair game' policies and 12 actions which had continued without change up to the time of the 13 settlement. I told him that I was being asked to betray 14 everything and everyone I had fought for against an organization 15 which was based upon injustice, 16 13. In answer to my objections to the settlement agreement, 17 Mr. Flynn said that the silence and liquidated damages clauses, 1E and anything which called for obstruction of justice were not 19 worth the paper they were printed on. He said the same thing a 20 number of times and a number of ways; e.g., that I could not 21 contract away my Constitutional rights; that the conditions were 22 unenforceable. He said that he had advised the organization 23 attorneys that those conditions in the settlement agreement were 24 not worth the paper they were printed on, but that the 25 organization, nevertheless, insisted on their inclusion in the 26 settlement agreement and would not agree to any changes. He 27 pointed out the clauses concerning my release of all claims 28 against the organization to date and its release of all claims against me to date (paras. 1,4,5,6,8) and said that they were the -8- \G3\Page.00009 1 essential elements of the settlement and were what the 2 organization was paying for. 3 14. Mr. Flynn also said that everyone was sick of the 4 litigation and wanted to get on with their lives. He said that he 5 was sick of the litigation, the threats to him and his family and 6 wanted out, He said that as a part of the settlement he and all 7 co-counsels had agreed to not become involved in organization- 8 related litigation in the future. He expressed a deep concern 9 that the courts in this country cannot deal with the organization 10 and its lawyers and their contemptuous abuse of the justice 11 system. He said that if I didn't sign the documents all I had to 12 look forward to was more years of harassment and misery. One of 13 Mr. Flynn's other clients, Edward Walters, who was in the room 14 , with us during this discussion, yelled at me, accusing me of 15 killing the settlement for everyone, and that everyone else had 16 signed or would sign, and everyone else wanted the settlement. . 17 Mr. Flynn said that the organization would only settle with 18 everyone together; otherwise there would be no settlement. He did 19 agree to ask the organization to include a clause in my settlement 20 agreement allowing me to keep my creative works relating to L. Ron 21 Hubbard or the organization (para. 7L). 22 - 15. Mr. Flynn said that a major reason for the settlement's 23 'global' form was to give the organization the opportunity to 24 change its combative attitude and behavior by removing the threat 25 he and his clients represented to it. He argued that the 26 organization's willingness to pay us substantial sums of money, 27 after its agents and attorneys had sworn for years to pay us 'not 28 one thin dime' was evidence of a philosophic shift within the organization. I argued that the settlement agreement evidenced 1 -9- 49 sl c \G3\Page.00010 1 the unchanged philosophy of fair game, and that if the 2 organization did not use the opportunity to transform its 3 antisocial nature and actions toward its members, critics and 4 society I would, a few years hence, because of my knowledge of 5 organization fraud and fair game, be again embroiled in its 6 litigation and targeted for extralegal attacks. 7 16. Regarding the affidavit the organization required that I 8 sign, Mr. Flynn said that the 'disagreement with prior management" 9 could be rationalized as being a disagreement with L. Ron Hubbard, 10 , and since Mr. Hubbard had died in January 1986 it could be said 11 that I no longer had that disagreement. Mr. Flynn said that the 12 organization's attorneys had promised that the affidavit, which 13 all the settling litigants were signing, would only be used by the 14 organization if I began attacking it after the settlement, and 15 since I had no intention of attacking the organization the 16 affidavit would never see the light of day. 17 17. During my meeting with Mr. Flynn in Los Angeles I found 18 myself facing a dilemma which I reasoned through in this way. If 19 I refused to sign the settlement agreement and affidavit all the 20 other settling litigants, many of whom had been flown to Los 21 Angeles in anticipation of a settlement, would be extremely 22 disappointed and would continue to be subjected to organization 23 harassment for an unknown period of time. I had been positioned 24 in the settlement drama as a deal-breaker and would undoubtedly 25 lose the support of some if not all of these litigants, several of 26 whom were key witnesses in my case against the organization. 27 Although I was certain that Mr. Flynn and my other lawyers would not refuse to represent me if I did not sign the documents I also knew that they all would view me as a deal-breaker and they would I - - 9 - - - I -. -----U~Rb \G3\Page.00011 1 be as disappointed as the other litigants in not ending the 2 litigation they desperately wanted out of. The prospect of 3 continuing the litigation with unhappy and unwilling attorneys on 4 my side, even though my cross-complaint was set for trial within 5 three months, was distressing. On the other hand, if I signed the 6 documents, all my co-litiggnts, some of whom I knew to be in 7 financial trouble, would be happy, the stress they felt would be 8 reduced and they could get on with their lives. Mr. Flynn and the 9 other lawyers would be happy and the threat to them and their 10 families would be removed. The organization would have the 11 opportunity they said they desired to clean up their act and start 12 anew. I would have the opportunity to get on with the next phase 13 of my life and~the financial wherewithal to do so. I was also not 14 u"happy to at that time not have to testify in all the litigation 15 nor to respond to the media's frequent questions. If the 16 organization continued its fair game practices toward me I knew 17 that I would be left to defend myself and I accepted that fact. 18 So, armed with Mr. Flynn's advice that the conditions I found so 19 ffensive in the settlement agreement were not worth the paper 20 hey were printed on, and the knowledge that the organization's 21 attorneys were also aware of that legal opinion, I put on a happy 22 face and the following day went through the charade of a 23 videotaped signing. 24 18. It was my understanding and intention at the time of the 25 1 settlement that I would honor the silence and confidentiality 26 conditions of the settlement agreement, and that the organization 27 had agreed to do likewise. 28 19. Following the December 1986 settlement the organization continued its fair game campaign against me in violation of the -11- \G3\Page.00012 1 spirit and letter of the settlement agreement. I detailed the 2 post-settlement violations I knew about in my declaration~of March 3 15, 1990, which was'filed in the Court of Appeal as an exhibit to 4 a document entitled 'Defendant's Reply to Appellants' Opposition 5 to Petition for Permission to File Response and for Time" and 6 served on the Los Angeles ~uperior Court on March 24, 1990, and my 7 declaration of December 25, 1990, which was filed in the Court of 8 Appeal as "Defendant's Appendix' to 'Defendant's Brief' and served 9 on the Los Angeles Superior Court on December 28, 1990. I request 10 that this Court take Judicial Notice of these declarations and the 11 exhibits thereto as they are part of the record in this case. 12 20. The organization's violations of the settlement 13 agreement include at least: 14 a) Use in 1987 of my name and a false and unfavorable 15 description of my organizational experiences.in a 'dead agent" 1~ pack relating to Bent Corydon, pages 11, 12, 18 and 29 from which 17 are attached hereto true and correct copies as Exhibit A; 18 b) Filing several false affidavits, attached herewith are 19 true and correct copies as Exhibit B (Kenneth David Long's First 20 - Affidavit dated October 5, 1987), Exhibit C (Kenneth Long's Second 21 Affidavit dated October 5, 1987), Exhibit D (Kenneth Long's Third 22 Affidavit dated October 5, 1987), Exhibit E (Sheila MacDonald 23 Chaleff's First Affidavit dated October 5, 1987), Exhibit F 24 (Kenneth Long's Fourth Affidavit dated October 7, 1987), and 25 Exhibit G (Kenneth Long's Fifth Affidavit dated October 8, 1987) 26, in the case of Church of Scientolosv of California v. Russell 27 Miller and Penquin Books Limited, Case no. 6140 in the High Court 28 of Justice in London England, accusing me of violations of court orders in the Armstrong case, and labeling me 'an admitted agent 1 \G3\Page.00013 1 provocateur of the U.S. Federal Government;' 2 c) Delivering a copy of an edited version of the 1984 3 illegal videotape of me, a photocopy of the cassette for which 4 showing the business card of organization private investigator 5 Eugene Ingram is attached herewith is a true and correct copy as 6 Exhibit H, to the London Sunday Times; 7 d) Threatening me with lawsuits on six occasions as set 8 forth in my March 15, 1990 and December 25, 1990 declarations of 9 which I have asked the Court to take judicial notice, above; 10 e) Threatening to release a description of a dream I had 11 had, and which the organization had stolen from a friend of mine, 12 if I did not assist them in preventing Bent Corydon from gaining 13 access to the Armstrons court file; 14 f) Using my name and a false rendition of the 15 organization's 1984 videotape operation where they attempted to 16 - entrap me into the commission of a crime in the Complaint filed in 17 the case of Church of Scientoloqv International v. 17 Asents, Case 18 No. 91-4301 SVW filed August 12, 1991 in US District Court, 19 Central District of California, page 14 from which is attached 20 herewith is a true and correct copy as Exhibit I; 21 g) Using the same false rendition of the 1984 "Armstrong 22 Operation,n perjurious declarations by organization lawyers and a 23 general attack on my character and truthfulness in various 24 pleadings filed in August 1991 in the case of Aznaran v. Church of 25 Scientoloqy of California, et al, No. CV 88-1786 JMI in U.s. 26 District Court, Central District of California. Exhibit J is a 27 true and correct copy of pages 2, 3, 33, and 34 of nReply in 28 Support of Defendants' Motion for Summary Judgment Based on the Statute of Limitations.' Exhibit K is a true and correct copy 1 \G3\Page.00014 1 which comprises pages 4, 5, and 6 of 'Supplemental Memorandum in 2 Support of Defendants' Motion to Dismiss Complaint with 3 Prej udice .' Exhibit L is a true and correct copy of pages 2 - 5 4 and pages 9 and 10 (the declaration of attorney Laurie J. 5 Bartilson dated August 27, 1991) of 'Defendants' Opposition to Ex 6 Parte Application to File Plaintiffs' Genuine Statement of Issues 7 Csic~ re Defendants' Motions (1) to Exclude Expert Testimony; and 8 (2) for Separate Trial on Issues of Releases and Waivers; Request 9 that Opposition Be Stricken.' I have included only a few pages 10 from these documents in the interest of economy, but will file the 11 , complete documents if the Court wishes. The organization has 12 included my declaration of September 3, 1991 'Regarding Alleged 13 'Taint' of Joseph A. Yanny, Esquire', also filed in the Aznaran 14 case in response to its allegations in these pleadings, as Exhibit 15 N to its motion to enforce the settlement. 16 21. Attached hereto as Exhibit M is a true and correct copy 17 of a Notice of Motion and Motion of Defendant Author Services, 18 Inc. to Delay or Prevent the Taking of Certain Third Party 19 Depositions by Plaintiff; Memorandum of Points and Authorities; 20 Declarations of Lawrence E. Heller and Howard Schomer in Support 21 Thereof filed on or about November 1, 1989 in the case entitled 22 Corydon v. Church of Scientolosv International, Inc.. et al., LASC 23 No. C694401. 24 22. In late 1987 I received a telephone call from a reporter 25 for the London Sunday Times who told me that the organization had 26 delivered to the newspaper a stack of documents concerning me, 27 including materials from the 1984 illegal videotape 'Armstrong 28 Operation,' and he asked me to comment about them. I was greatly saddened by this news, but told the reporter only that I ~ps~pis -------- ' -- \G3\Page.00015 1 considered the organization's action a violation of its agreement 2 with me and I would not comment further. 3 23. When I was threatened in 1988 with exposure of the 4 stolen dream recitation (see 3-15-90 declaration, para. 40), I 5 considered I was being blackmailed. In the hope that by my 6 example I would deter further such conduct, I did not violate the 7 settlement agreement. I learned this past August 1991 in 8 Johannesburg, South Africa that the organization had given a copy 9 of the dream recitation, which had been specifically sealed in the 10 Armstronq litigation, to its representatives in that country. 11 24. When I had several times been threatened by organization 12 attorney Larry Heller that I would be sued if I did not obstruct 13 'justice as directed by the organization, and when it had become 14 obvious to me that I could not avoid a confrontation with the 15 organization (see 3-15-90 declaration, paras. 4-8, 44) didI 16 respond to defend myself and to correct the injustices created by 17 the settlement agreement and the organization's violations 18 thereof. 19 25. The first action I took was to file on February 28, 1990 20 in the California Court of Appeal, Second Appellate District, in 21 the appeal the organization had maintained from the June 20, 1984 22 decision in Armstrons, a document entitled Respondent's Petition 23 for Permission to File Response and for an Extension of Time to 24 File Response,' attached hereto as Exhibit N. I did so in part 25 because in my research of my rights following my recognition that 26 I could not avoid involvement I discovered that my agreement to 27 not respond pursuant to the settlement contract was an obstruction 28 of justice. After the Court of Appeal granted my petition on March 9, 1990, I did thereafter file a respondent's brief. SICBI s - ~- ~ss \G3\Page.00016 1 Thereafter, on July 29, 1991 an opinion issued in that appeal 2 upholding the trial court's decision on the merits. 3 I declare under the penalty of perjury under the laws of the 4 State of California that the foregoing is true and correct. 5 Executed this 17th day of November, at San Anselmo, 6 California. 7 8 Gerald Armstrong 9 10 11 12 13 14 15 16 17 18 lc 20 21 22 23 24 25 26 27 28 r- el ~SPQI --~- \G3\Page.00016 1 Thereafter, on July 29, 1991 an opinion issued in that appeal 2 upholding the trial court's decision on the merits. 3 I declare under the penalty of perjury under the laws of the 4 State of California that the foregoing is true and correct. 5 Executed this 17th day of November, at San Anselmo, 6 California. 7 8 Gerald Armstrong 9 10 11 12 13 14 15 16 17 18 lc 20 21 22 23 24 25 26 27 28 r- el ~SPQI --~- ================================================================= If this is a copyrighted work, you are acknowledging by receipt of this document from FACTNet that on the basis of reasonable investigation, you have not been to obtain a copy elsewhere at a fair price, and that you are and will abide by the following copyright warning. 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