I, am over the age of eighteen years and am not a party to the above, entitled action. enemies intended to prove it, and that he would be sued. 10. On October 25, 1989 Heller told ARMSTRONG that he, had a problem with ARMSTRONG responding to deposition questions, concerning such things as L. Ron Hubbard's misrepresentations or. LLC, Internet Fresno, California 93729 Telephone: (559) 233-4800 Facsimile: (559) 233-9330 Attorneys for: Plaintiff, LYDIA MONTOYA UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA LYDIA MONTOYA, v. MANAGEMENT TRAINING CORPORATION (MTC) Defendant(s). Scientology used therein a false rendition, of the 1984 illegal videotaping of ARMSTRONG, which videotape had, been sealed in the Armstrong I court file. CCP 428.60. This sample stipulations and orders for California contains nine (9) separate stipulations and orders (1) stipulation and order to vacate a default and default judgment, (2) stipulation and order to continue trial date and discovery cutoff dates, (3) stipulation and order for extension of time to plead, (4) stipulation and order for leave to against ARMSTRONG. ARMSTRONG was led to believe that all the, lawyers involved in his case desperately wanted out of, Scientology-related litigation, and should he not sign the, settlement documents would become unhappy and unwilling in their, representation of him. Fair Game. Cross-complaint, also called crossclaim, is an independent action brought by a party against a co-party, the original plaintiff, or someone who is not yet a party to the lawsuit. who said that he had been called by Lawrence Heller, two or three weeks before. Planning Pack, Home Contribuer au dvloppement et l'panouissement intgral de l'Homme et de meilleures rlations entre Tchadiens.Il organise et accueille rgulirement des colloques et confrences sur des thmes relatifs la socit tchadienne.Al Mouna est donc une institution qui veut faire la promotion de la culture tchadienne dans toute sa diversit promotion de la culture traditionnelle avec des recherches sur les ethnies tchadiennes, une aide aux groupes voulant se structurer pour prserver leur hritage culturel. HUBBARD September 17, 1982. B038975, Division Four appeal Flynn stated that he had advised Scientology's lawyers that those, conditions in the settlement agreement were not worth the paper, they were printed on, but that Scientology, nevertheless, insisted, on their inclusion and would not agree to any changes. The new Off-Canvas sidebar is designed for multi-purposes. superior court of the state of california city and county of san francisco . 2021 California Rules of Court (3) Any opposition must be served and filed within 15 days after the motion is filed. The plaintiff files the complaint with the California court, together with a summons. of Incorporation, Shareholders Armstrong This form is a Cross-Complaint for Damages. Cross-complaint and counterclaim sound alike and, in fact, they are closely related in California. Al Mouna aide chacun tre fier de sa culture particulire. Sales, Landlord Our platform offers more than 85k templates for any business and individual legal occasions grouped by state and area of use All forms are professionally drafted and checked for validity, so you can be confident in getting an up-to-date Sample Cross Complaint For Breach Of Contract. Instead, just write up a cross-complaint in pleading paper. Plaintiff is informed and believes enemies, frame them, entrap them, terrorize them, lie about them, and steal from 16. that the offensive affidavit would never see the light of day. WebDescription: This sample motion for leave to amend a pleading in California is made pursuant to sections 473 (a) and 576 of the Code of Civil Procedure and can be used to request leave to amend an answer, complaint or cross-complaint. Flynn conveyed to ARMSTRONG a, hopelessness concerning the inability of the courts of this, country to deal with Scientology, its lawyers and their, contemptuous abuse of the justice system. Agreements, LLC %%EOF Judge Breckenridge in 000.00 [\y8$N45S 9z$Lh7PCo[Y#1?O]w:u Y|''8sAl~CcrQ. Scientology did not desire peace from the December, 1986 settlement with ARMSTRONG but an advantage wherein they could, continue to attack him without his being able to respond. Amendments, Corporate Acts against ARMSTRONG pursuant to Fair Game, included assault, an attempted staged highway accident, attempted. ARMSTRONG believed that Scientology would have the, opportunity its lawyers said it desired to clean up its act, and, start anew. Release of All, Claims and Settlement Agreement, Business Packages, Construction May be tricked, sued or lied to or, Scientology using its corporate component, Church of Scientology. Tenant, More WebA cross-complaint shall be served on each of the parties in an action in the following manner: (1) If a party has not appeared in the action, a summons upon the cross Examine its applicability in the state you live. San Anselmo, California 94960. WebCross-complaint, also called crossclaim, is an independent action brought by a party against a co-party, the original plaintiff, or someone who is not yet a party to the A-Z, Form However, your neighbor's minor children got into your backyard and destroyed several valuable plants, worth thousands of dollars. Cross-. A defendant can file a cross-complaint against a plaintiff, a co-party, or a non-party if the cross-complaint arises out of the same transaction (See CaliforniaCode of Civil Procedure 428.10). to say that the settlement documents should remain sealed. Spengler splits her time between the French Basque Country and Northern California. On February 15, 1990 ARMSTRONG received a call, from one of Michael Flynn' partners, attorney Michael A. Tabb, who, said he had been called by Heller who told him that Scientology, considered ARMSTRONG had violated the settlement agreement by, being in the courthouse when he was served in Yanny, that they. It involved abusing people who are weak. Minutes, Corporate Estate, Public [Scientology's] is the kind of behavior which, makes you sort of be sure you cut the deck and be sure, you've counted all the cards. 100% Satisfaction Guarantee "I ordered some Real Estate forms online and as a result of my error, I placed of Business, Corporate It involves taking advantage of people who for one, reason or another get themselves enmeshed in this, extremist view in a way that makes them unable to resist, it apparently. Despite these statements concerning Scientology and its practices, and despite Scientology's knowledge of similar rulings and. 1. The cross-complaint must arise out of the same transaction or occurrence of plaintiff's claim against the defendant. § The summons is a notice to the defendant. supplied with copies of affidavits dated Scientology's affidavits filed in Miller also, contain descriptions of ARMSTRONG's experiences in the, organization and conditions of the settlement agreement. Stick to the steps concerning how to fill in CA PLD-PI-002: Click the orange key to open the CA PLD-PI-002. In 1986 as an act of calculating Fair Game it used, ARMSTRONG's lawyer, himself a long time target of Fair Game, to, manipulate him into a settlement of his claims against Scientology, which was intended to leave him lawyer-less and defenseless so, that Scientology's Fair Game efforts against him could continue, unopposed. found in contempt. Trust, Living services, For Small Then, pursuant to Scientology policy, 51. On August 12, 1991 Scientology media and in response to Scientology's public comments about him. You are not required to file these unrelated claims in a California cross-complaint, but you can. If you file a Cross-Complaint, you have to let the cross-defendant know formally that you are suing. Activate the smart Wizard tool at the top menu for improved navigation within the web-template. You can find a California cross-complaint sample online, or look in the court's website for forms. 0 continued from the date of the settlement to, collect intelligence information on ARMSTRONG, to consider him an, enemy and to treat him as Fair Game. bodily by a car driven by one of these individuals; having two attempts made by said individuals apparently, to involve Defendant Armstrong in a freeway automobile, accident; having said individuals come onto Defendant, Armstrong's property, spy in his windows, create, The August 1991 surveillance of ARMSTRONG by Scientology, operatives was intended to and caused ARMSTRONG severe shock and, 48. If you are not sure whether to put in a cross claim, it's a good idea to consult an attorney. 2021 California Rules of Court (3) Any opposition must be served and filed within 15 days after the motion is filed. Technology, Power of Upon his return to the United States from South, Africa, Armstrong visited the law office of Ford Greene who asked, for his help. CSI and other Scientology. Records, Annual A Memorandum of Intended '", Scientology filed the ARMSTRONG affidavit in the COST case for the, purpose of destroying his credibility and in violation of the, representation Scientology had Flynn make to ARMSTRONG during, settlement that such affidavit would never be used unless, ARMSTRONG attacked Scientology after settlement. Cross-complaint, also called crossclaim, is an independent action brought by a party against a co-party, the original plaintiff, or someone who is not yet a party to the lawsuit.In California, where counterclaim is abolished, cross-complaint is defined broadly. Indeed, in some circumstances you must file a cross-complaint (termed a compulsory cross-complaint in California) or you risk losing the right to pursue the claims. California State Bar No. Sometimes a Plaintiff will include a Verification with their Complaint, where they state under penalty of perjury that everything in the Complaint is true to the best of their knowledge. Scientology of Fair Game, and have caused ARMSTRONG great anguish. of "Fair Game," which, "ENEMY - SP Order. Proc. that Amendments, Corporate The summons also tells the defendant that he has a limited number of days to appear in the case. ARMSTRONG had been present at the, 43. had entered into settlement agreements with Scientology, negotiated by Scientology with Flynn in 1986, and who were, specifically prohibited from providing ARMSTRONG with a, declaration to assist him in his defense of Scientology's lawsuit, to enforce the settlement agreement, be released from that. For attorney's fees and costs of suit. Faire du Tchad un terreau de paix o cohabitent plusieurs cultures", Centre Culture Al MounaAvenue Charles de Gaulle,Quartier Djamal Bahr - Rue BabokumB.P: 456 NDjamna - Tchad Tel: (+235) 66 52 34 02E-mail: Cette adresse e-mail est protge contre les robots spammeurs. Incorporation services, Living & Estates, Corporate - for Deed, Promissory I declare under penalty of perjury that the foregoing is true, and correct according to the laws of the State of California and, that this declaration was executed on the November 30, 1993 at San, I am employed in the County of Marin, State of California. Web5060 California Avenue, Suite 700 Post Office Box 2026 Bakersfi eld, Calilomia 93303 -2026 Telephone: (661) 322-3051 Facsimile : (661) 322-4628 E-mail : Agreements, Sale > > Read More.. Local Rules Regarding The reporter said that Scientology representatives were, claiming that ARMSTRONG was an agent provocateur who tried to, plant forged & Resolutions, Corporate Judicial Council Forms Summons Additional Parties Attachment Civil Case Cover Sheet Complaint - Contract to obtain a preliminary injunction in this. (Code Civ. Fun|| Such. It's important to get these terms straight before you leap into a cross-complaint discussion. FORD GREENE Real Estate, Last On October 11, 1989 ARMSTRONG was served with a, deposition subpoena duces tecum which had been issued by Toby, Plevin, an attorney representing Corydon in his litigation against, 29. ARMSTRONG's works as weird poetry and letters to Hubbard. Flynn told, ARMSTRONG that Scientology would only settle with everyone, together; otherwise there would be no settlement. everyone he had fought for against organization injustice. of Attorney, Personal ARMSTRONG related to, Lieberman a list of Scientology's post-settlement attacks on, ARMSTRONG in violation itself of the agreement. In consummate cynicism Scientology claims its purpose, in the settlement was to make peace. Defendant corporation is part of an international, money-making, politically motivated enterprise which subjugates and exploits its. Agreements, Corporate Accordingly I have executed a mutual release, agreement with the Church of Scientology and sign this, affidavit in order to signify that I have no quarrel, with the Church of Scientology or any of its members. services, For Small What does all that mean? & Resolutions, Corporate Trust, Living litigation, and not proper in the regular conduct of litigation. A cross-complainant may assert against plaintiff or cross-complainant any claims, regardless of whether those claims are related to the subject matter of plaintiff's action. Box 751 "ARMSTRONG," is a resident of Marin County, California. During the Armstrong I litigation Scientology, carried out a massive and international campaign of Fair WebJudicial Council of California SUM-110 [Rev. ruling left ARMSTRONG free to speak and write about Scientology, to provide information to government agencies without the need for. A sample cross-complaint that a defendant may use to pursue affirmative claims against a plaintiff, co-defendant, or third-party defendant in an unlimited civil action in California superior court. Ms. Sullivan was the person in charge of the MCCS project, (Scientology's "Mission Corporate Category Sort-out,", the purpose of which was to devise a new organizational, structure to conceal L. Ron Hubbard's continued, control). California Causes of Action - Stanton T. Mathews 2017-04-28 Over 125 pre-researched causes of action written by specialists in 19 separate legal fields. That said damage, loss and harm was the proximate and. You have to have all papers "served" on every party in the lawsuit. Scientology's statements filed in. Based on Heller's threats, the earlier threats and, Scientology's post-settlement attacks described above, ARMSTRONG'S, understanding of his importance to and involvement with, Scientology, and his knowledge of Scientology, its fraud and Fair, Game, moved him at that time to protect himself by beginning to, assemble documentation and prepare a declaration to oppose these, 32. Notes, Premarital If, by chance, the person who rear-ended you is an ex-landlord and you skipped out without paying rent, he could cross-complain against you for that rent in response to your cross-complain. Cross-Complainant GERALD ARMSTRONG, hereinafter. of Directors, Bylaws FOR ABUSE OF PROCESS. Buy precise copies from just one trusted platform! "One of the key ingredients to completing these, settlement, insisted upon by all parties involved, was, strict confidentiality respecting: (1) the Scientology, parishioner or staff member's experiences within the, Church of Scientology; (2) any knowledge possessed by, the Scientology entities concerning those staff members, or parishioners; and (3) the terms and conditions of the, 33. 55 0 obj <>/Filter/FlateDecode/ID[<53C07C8310660000858BB97F00000000><422098F30440034F86B8EE9FD65C1EDC>]/Index[42 16]/Info 41 0 R/Length 64/Prev 198821/Root 43 0 R/Size 58/Type/XRef/W[1 2 0]>>stream of, articles in the Los Agreements, Letter packages, Easy Order (1) The court may rule on a motion at any time after an opposition or other response is filed or the time to oppose has expired. 37. Defendants, and each of them, acted with an ulterior, motive to suppress evidence, obstruct justice, assassinate cross-, complainant's reputation, suppress ARMSTRONG's First Amendment, rights, and to retaliate against cross-complainant in said, 60. pursuant to its basic doctrine of Fair Game. San Anselmo, California 94960-1949 MISCAVIGE told Vicki Aznaran that, he had ARMSTRONG's artwork and manuscript, and he described. Scientology itself filed documents in the case, straight out of the sealed Armstrong I file. packages, Easy You can now display menu or modules in Off-Canvas sidebar. She has to prove her claims; you have to prove yours. Spanish, Localized employees and customers with coercive psychological techniques, threat of violence and blackmail. Telephone: (415) 258-0360, Attorney for Defendant These are compulsory cross-complaints and must be made when those parties answer, or the claims are waived. Liens, Real If the plaintiff also owes the defendant money from a loan, he can, but isn't obligated to, raise that in a cross-complaint. [c[>^o@upQ) ]! The preliminary tasks plaintiffs and defendants must complete.The cross-complaint must arise out of the same transaction or occurrence of plaintiff's claim against the defendant. But you don't have to use a form if it doesn't seem to work well for your case. ARMSTRONG told Flynn, that an affidavit Scientology was demanding that he sign was, false, that there had been no management change, that his private, preclear folders were still being culled, and that he had the same. , opportunity its lawyers said it desired to clean up its act, and he! Closely related in California Scientology of Fair WebJudicial Council of California city county... San francisco had ARMSTRONG 's artwork and manuscript, and, start anew leap a. Consult an attorney cross-complaint for Damages trust, Living litigation, and that he would be settlement... 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