GERRY ARMSTRONG
C/O DIALOG ZENTRUM BERLIN
Heimat 27
D-14165 Berlin-Zehlendorf
Germany
Tel: +49(0)30-8157040
Fax: +49 (0) 1212-5-205-27-015
gerry@gerryarmstrong.org
In Propria Persona

SUPERIOR COURT OF CALIFORNIA
COUNTY OF MARIN

Case No. CV 021632

CHURCH OF SCIENTOLOGY INTERNATIONAL,
Plaintiff,
vs.
GERALD ARMSTRONG; et al.,
Defendants.

ANSWER OF GERRY ARMSTRONG

ANSWER

INTRODUCTION

Defendant Gerry Armstrong, hereinafter "Armstrong," hereby submits the following answer to the complaint of plaintiff, Church of Scientology International, hereinafter "CSI." CSI is a single component of the global Scientology organization, hereinafter "Scientology," that, along with all of the Scientology-related beneficiaries of the settlement, which underlies their complaint that is answered hereby, are subject to a unity of control exercised by David Miscavige, hereinafter "Miscavige." The Scientology-related beneficiaries of the settlement, hereinafter the "beneficiaries," include, but are not limited to, all Scientology and Scientology affiliated organizations and entities world wide, including Church of Spiritual Technology, and their officers, agents, representatives, employees, volunteers, directors, successors, assigns and legal counsel, including Sherman Lenske. Plaintiff and all other Scientology-related organizations, entities and individual beneficiaries were created by David Miscavige and his attorneys as an attempt to avoid payment of taxes and civil judgments and to confuse courts and those seeking redress for the civil and criminal misconduct of Miscavige and all other Scientology-related organizations, entities and individuals. Due to the unity of personnel, commingling of assets, and commonality of business objectives, any effort by CSI to separate itself as being independent and separate should be disregarded.

1. Armstrong admits that there was a Mutual Release of All Claims and Settlement Agreement, hereinafter "mutual release," entered into in December 1986 between him and CSI, Scientology, Miscavige and other beneficiaries of the mutual release. Armstrong denies that CSI, Scientology, Miscavige or any of the beneficiaries have been damaged in any way whatsoever by anything Armstrong has done at any time which could possibly be construed as a breach of the mutual release. CSI's, Scientology's, Miscavige's and the beneficiaries' motive for bringing this action is not to recover damages, because there have been and are no damages, but to destroy Armstrong pursuant to CSI's, Scientology's, Miscavige's and the beneficiaries' basic philosophy, policy and practice of "fair game" and their basic litigation policy of "using the law to harass and ruin utterly" their fair game targets. Scientology founder L. Ron Hubbard, hereinafter "Hubbard," detailed by published policy how CSI, Scientology, Miscavige and the beneficiaries are to treat fair game targets such as Armstrong: "ENEMY - SP Order. Fair game. May be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. May be tricked, sued or lied to or destroyed." Armstrong has been designated an "enemy" of Scientology, Miscavige and all the beneficiaries and a target of their fair game doctrine since 1981.

2. Armstrong denies that beginning in late 1989 he systematically began breaching virtually every material covenant to which he had agreed by entering into the mutual release, or that at any time he breached any material covenant whatsoever to which he had agreed by entering into the mutual release. The conditions that CSI, Scientology, Miscavige and the beneficiaries characterize as "material covenants" are not material at all, but against public policy, illegal, judicially unenforceable and severable from the actual material covenants of the mutual release. Armstrong breached no material covenant of the mutual release whatsoever, but performed each and every one of the material covenants to which he had agreed by entering into the mutual release. Armstrong admits that in 1992, CSI instituted suit against him, but denies that CSI, Scientology, Miscavige or the beneficiaries sought damages for his repeated breaches of the mutual release, since there were no damages. Because of their hatred for Armstrong, and pursuant to their fair game doctrine and policy of using the law to harass and ruin utterly their fair game targets, CSI, Scientology, Miscavige and the beneficiaries sought to destroy him by using the Law of the California Courts to enforce the mutual release's anti-public policy, illegal, and immaterial conditions. Armstrong admits that CSI, Scientology, Miscavige and the beneficiaries sought provisional and permanent injunctive relief against future breaches. Armstrong admits that CSI obtained a monetary judgment and a permanent injunction in this Court. Armstrong admits that he has characterized this Court's injunction as "illegal," "unconstitutional," and "a great stupidity," and he avers that he has characterized the injunction moreover as impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, even insane. Armstrong further admits that because this Court's injunction is illegal, unconstitutional, a great stupidity, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, and even insane, Armstrong continually violates its terms. Armstrong admits that he has been found by this Court to be in contempt on two separate occasions, citing 14 separate violations, and is the subject of two outstanding bench warrants, but denies that this was as a result of his beginning almost immediately to violate the terms of the injunction. Armstrong was found by this Court to be in contempt on two separate occasions, citing 14 separate violations, and is the subject of two outstanding bench warrants, as a result of this Court improperly, even illegally, abetting CSI's, Scientology's, Miscavige's and the beneficiaries' fair gaming of Armstrong by illicitly giving this Court's power and authority to CSI, Scientology, Miscavige and the beneficiaries to harass and utterly ruin Armstrong, including by this Court's issuance of its illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane injunction. Armstrong admits that on July 13, 2001 he was again found to be in contempt of the injunction on no less than 131 additional occasions. Armstrong also admits that on July 13, 2001 he was found to be in contempt of the injunction on no more than 131 additional occasions. Armstrong denies that he has evaded both the fines and the imprisonment to which he has been sentenced by fleeing the jurisdiction and relocating to British Columbia, Canada. Armstrong left Marin County, California in January 1997, because of unceasing fair game being perpetrated against him by CSI, Scientology, Miscavige and the beneficiaries abetted by this Court, because of continuing threats to Armstrong's livelihood, reputation and life by CSI, Scientology, Miscavige and the beneficiaries abetted by this Court, and immediately at that time in January 1997 because of Armstrong's discovery of a lengthy fair game "Black Propaganda," attack on him by CSI, Scientology, Miscavige and the beneficiaries in their IRS Form 1023 Submission to the Internal Revenue on which their 1993 tax exemption is based. Black Propaganda, hereinafter "black PR," is the term Hubbard directed be used and Scientology uses for its policy and practice of destroying a fair game target's reputation, credibility and life with covert and overt, relentless and pervasive libel and slander. CSI, Scientology, Miscavige and the beneficiaries obtained their first fines and order of imprisonment against Armstrong from this Court, without notice to him and based on false and misleading statements, many months after he had left Marin County and relocated in British Columbia.

3. Armstrong denies that this action seeks redress for a total of 201 breaches of paragraph 7D of the mutual release. This action seeks to illegally fair game Armstrong into silence, using the power and authority and the appearance of legality, probity and justice of this Court, to punish Armstrong for speaking the truth about CSI, Scientology, Miscavige and the beneficiaries and fair game, black PR, use of the law to harass and ruin utterly, and their other illegal and noxious policies, practices and acts, and, through the illegal fair gaming and illegal judicial silencing and punishing of Armstrong, to rewrite their antisocial and criminal history which he knows and speak about. Armstrong admits that CSI, Scientology, Miscavige and the beneficiaries assert claims for breach of contract against him and claims for intentional interference with contractual relations against Robert Minton, hereinafter "Minton," and the Lisa McPherson Trust, hereinafter the "LMT." Armstrong denies that the financial resources of Minton or the LMT were intended to, and specifically enabled them to act in concert and conspiracy with Armstrong to perpetuate his ongoing contempt of this Court and to violate on virtually a daily basis CSI's contractual rights. Armstrong denies that CSI, Scientology, Miscavige or any of the beneficiaries have any legal contractual right whatsoever to legally prevent Armstrong from doing anything he has done, nor to legally prevent Minton or the LMT or anyone else from acting in concert and conspiracy, or in concert, or in conspiracy, with Armstrong or without Armstrong, in doing anything he has done. Whatever Armstrong has done is not contempt of this Court, because this Court's injunction is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane, and a person cannot legally be held in contempt of any court for violating an injunction or any other court order which is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane. Armstrong moreover cannot either admit or deny CSI's averment that Minton's and the LMT's "financial resources were intended to, and specifically enabled them to act in concert and conspiracy with Armstrong " because this averment is unintelligible, nonsensical or both.

4. Armstrong admits that Plaintiff CSI's headquarters are located in Los Angeles, California, and that it has been granted the status of a nonprofit religious corporation organized and existing under the laws of the State of California. Armstrong denies that CSI is in fact a non-profit religious corporation, but is a profit-driven cult of intelligence, utterly irreligious in nature and involved in activities and practices antithetical to the laws of California, the United States, the world community, and God.

5. Armstrong admits that he was a long-time resident of Marin County. He denies that he is presently or has ever been a fugitive from this jurisdiction. Armstrong admits that he is a fugitive from injustice. He admits that he is a fugitive from CSI's, Scientology's, Miscavige's and the beneficiaries' illegal fair gaming of him abetted by this Court. Armstrong denies that Judge Thomas entered any injunction on May 28, 1992. Armstrong denies that the orders of this Court finding him in contempt of court concerned in any way violations of any injunction entered on May 28, 1992. Armstrong denies that any of this Court's contempt of court orders against him were criminal contempt convictions. Armstrong denies that he fled Marin County and relocated in Canada to avoid incarceration for any criminal contempt convictions or from any orders of civil contempt. Armstrong avers that he was driven from his home in Marin County in January, 1997 because of unceasing fair game being perpetrated against him by CSI, Scientology, Miscavige and the beneficiaries abetted by this Court, because of continuing threats to his livelihood, reputation and life by CSI, Scientology, Miscavige and the beneficiaries abetted by this Court, and immediately at that time because of his discovery of a lengthy fair game Black PR attack on him by CSI, Scientology, Miscavige and the beneficiaries in their IRS Form 1023 Submission to the Internal Revenue on which their 1993 tax exemption is based. CSI, Scientology, Miscavige and the beneficiaries obtained their first order of contempt against Armstrong from this Court, without notice to him and based on false and misleading statements, many months after he had left Marin County and relocated in British Columbia.

6. Armstrong admits that Minton is an individual. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that Minton maintains multiple residences in Massachusetts, New Hampshire, Florida, and perhaps elsewhere, and is therefore unable to admit or deny the same.

7. Armstrong denies that the LMT's name is either deceptive or misleading. Armstrong admits that the LMT was a for-profit corporation, organized and existing under the laws of the State of Florida, with its principal place of business in Clearwater, Florida. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averments that the LMT was dissolved in December 2001 or that Minton is its founder, sole incorporator, and the source of its financing, and Armstrong is therefore unable to admit or deny the same.

8. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that the LMT is, and at all times since its incorporation was, the alter ego of Minton and there exists, and at all times since the LMT's incorporation has existed, a unity of interest and ownership between these two defendants such that any separateness between them has ceased to exist, and Armstrong is therefore unable to admit or deny the same. Armstrong denies that Minton has completely controlled, dominated, managed and operated the LMT since its incorporation for his own personal benefit.

9. Armstrong denies that the LMT is, and at all times herein mentioned was, a mere shell, instrumentality and conduit through which defendant Minton carried on his own activities in the corporate name, exercising such complete control and dominance of the activities of the LMT to such an extent that any individuality or separateness of the LMT and Minton does not, and at all relevant times mentioned herein, did not exist. Armstrong denies that the LMT made the barest pretense of adherence to corporate formalities. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that Minton sold his entire interest in the LMT to Stacy Brooks, hereinafter "Stacy," for the sum of one dollar, and is therefore unable to admit or deny the same. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that Stacy is Minton's mistress, and is therefore unable to admit or deny the same. Armstrong denies that Minton continues to exercise complete control over the LMT. Armstrong denies that Stacy ran the LMT's affairs entirely under Minton's direction and for his benefit. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that Stacy is the President and sole shareholder of LMT, and is therefore unable to admit or deny the same. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that following the nominal transfer of ownership, Minton continued to finance the LMT's operations, and is therefore unable to admit or deny the same. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that Minton's control of the LMT's finances was, or is, illustrated by the fact that he arranged for anonymous donors to transfer in excess of $500,000 to the LMT's bank accounts, and is therefore unable to admit or deny the same. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averments that upon receipt of any funds by the LMT, Stacy immediately paid them out to Minton as a "repayment" of undocumented "loans" now claimed to be owed Minton by LMT, that such undocumented loans existed, or did not exist, that Minton now claims he is owed anything by the LMT, that Minton ever claimed he was owed anything by the LMT, or that anyone else is claiming or ever claimed that Minton was owed anything by the LMT, and Armstrong is therefore unable to admit or deny the same.

10. Armstrong denies that the separate existence of the LMT as an entity distinct and apart from Minton is a fiction, and Armstrong therefore denies that any adherence to the fact of the separate existence of the LMT as an entity distinct and apart from Minton would permit any abuse of the corporate privilege or would promote any injustice. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that Minton has in any way used the LMT as a means of financing, supporting, and enabling him to do anything, and is therefore unable to admit or deny the same. Armstrong denies that anything Minton or the LMT have done to finance, support or enable Armstrong does not finance, support or enable Armstrong to breach the mutual release on virtually a daily basis, or on any other basis. Armstrong has performed each and every one of the covenants to which he had agreed by entering into the mutual release, which were not illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical or insane.

11. Armstrong denies that the activities of the LMT and Minton are and have been regular and systematic, or are or have been regular and systematic, or are and have been regular or systematic, or are or have been regular or systematic, throughout California since its incorporation in 1999, or at any other time. Armstrong denies that California was incorporated in 1999. Armstrong denies that indeed seven of the LMT's key officials as identified in the LMT's own materials, are citizens and residents of California. Armstrong denies that indeed seven of the LMT's key officials as identified in the LMT's own materials, are not resident or officed in Florida. Armstrong denies that the LMT's own materials identify seven key officials of all of its key or unkey officials from any or all states of the United States or from any or all of the countries of the world. Armstrong denies that any members of the LMT's Advisory Board are key officials in the LMT, or have ever been key officials in the LMT. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averments that seven members of the LMT's Advisory Board are citizens and residents of California, or that any members of the LMT's Advisory Board are citizens and residents of California, and Armstrong is therefore unable to admit or deny the same. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that he himself is a member of LMT's Advisory Board, and is therefore unable to admit or deny the same. Armstrong admits that he has in the past been a member of the LMT's Advisory Board. Armstrong denies that he was ever or at any time a resident of Marin County or any other California county on or after the date of incorporation of the LMT. Armstrong denies that he was a Marin County resident until he absconded to Canada to avoid paying his fines and serving his jail time. Armstrong repeats his averment that he was driven from his home in Marin County in January, 1997 because of unceasing fair game being perpetrated against him by CSI, Scientology, Miscavige and the beneficiaries, abetted by this Court, because of continuing threats to his livelihood, reputation and life by CSI, Scientology, Miscavige and the beneficiaries, abetted by this Court, and immediately at that time because of his discovery of a lengthy fair game Black PR attack on him by CSI, Scientology, Miscavige and the beneficiaries in their IRS Form 1023 Submission to the Internal Revenue on which their 1993 tax exemption is based. CSI, Scientology, Miscavige and the beneficiaries obtained their fines and jail sentences against Armstrong from this Court, without notice to him and based on false and misleading statements, many months after he had left Marin County and relocated in Canada. Armstrong denies that the LMT is Minton's alter ego. Armstrong denies that flouting an injunction issued by this Court which is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane directly or indirectly interferes in any way with the lawful authority of the courts of the State of California. Armstrong denies that either Minton or the LMT through any of their actions have in any way directly or indirectly interfered with the lawful authority of the courts of the State of California.

12. Armstrong denies that at any time he combined, conspired or agreed with Minton or the LMT to perform any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint. Armstrong denies that any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint are unlawful. Armstrong denies that he combined, conspired or agreed with Minton or the LMT to conceal from discovery any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint. Armstrong repeats his denial that any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint are unlawful. Armstrong denies that he combined, conspired or agreed with Minton or the LMT to conceal from discovery the participation of Minton and LMT, or Minton or the LMT, in any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint. Armstrong denies that any participation whatsoever of Minton or the LMT in any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint was unlawful or conspiratorial. Armstrong again repeats his denial that any of the acts which are the subject of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint are unlawful.

13. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that the true names and capacities of the persons and/or entities that are sued by CSI, Scientology, Miscavige or the beneficiaries as defendant DOES 1 through 50, inclusive, are unknown to CSI, Scientology, Miscavige or the beneficiaries at this time, and Armstrong is therefore unable to admit or deny the same. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that therefore CSI, Scientology, Miscavige or the beneficiaries are suing said defendants by such fictitious names, and Armstrong is therefore unable to admit or deny the same. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that CSI, Scientology, Miscavige or the beneficiaries will amend the complaint to show the true names and capacities of defendant DOES 1 through 50, inclusive when the same are ascertained, and is therefore unable to admit or deny the same. Armstrong denies that CSI, Scientology, Miscavige or the beneficiaries are informed and believe that each of the DOE defendants is responsible in some manner for the acts that CSI, Scientology, Miscavige or the beneficiaries complain of in their complaint. Armstrong admits that CSI, Scientology, Miscavige and the beneficiaries just allege it.

14. Armstrong admits that on December 6, 1986 CSI, plus Scientology, plus Miscavige, plus all the beneficiaries entered into a settlement with Armstrong, and that a true and correct copy of the mutual release relating to such settlement is attached to CSI's, Scientology's, Miscavige's and the beneficiaries' complaint as Exhibit A thereto and incorporated by reference therein. Armstrong denies that the mutual release was designed to end, once and for all, or in any way, any litigation, bitter or not bitter, including or not including several separate cases then pending. Armstrong denies that his litigation against CSI, Scientology, Miscavige or any of the beneficiaries was bitter. Armstrong admits that all of the litigations of CSI, Scientology, Miscavige and the beneficiaries were bitter, and were, moreover, abusive, dishonest, unjust, threatening, hateful and diabolic. CSI, Scientology, Miscavige and the beneficiaries designed the mutual release so they could continue their bitter, abusive, dishonest, unjust, threatening, hateful and diabolic litigations against Armstrong and their other fair game targets, continue their fair gaming of Armstrong and their other targets, continue to use the law to harass and destroy utterly Armstrong and their other targets, and to rewrite their histories, without Armstrong being able to respond in any way to CSI's, Scientology's, Miscavige's and the beneficiaries' bitter, abusive, dishonest, unjust, threatening, hateful and diabolic litigations against Armstrong and their other fair game targets, without Armstrong being able to respond to CSI's, Scientology's, Miscavige's and the beneficiaries' continuing to fair game Armstrong and their other targets, without Armstrong being able to respond to CSI's, Scientology's, Miscavige's and the beneficiaries' continuing to use the law to harass and destroy utterly Armstrong and their other targets, and without Armstrong being able to respond to CSI's, Scientology's, Miscavige's and the beneficiaries' rewriting of their histories; and to harass, punish and utterly ruin Armstrong, using the power and authority and the appearance of legality, probity and justice of the courts of California and the United States, if Armstrong responded in any way to CSI's, Scientology's, Miscavige's and the beneficiaries' bitter, abusive, dishonest, unjust, threatening, hateful and diabolic litigations against Armstrong and their other fair game targets, if he responded in any way to CSI's, Scientology's, Miscavige's and the beneficiaries' continuing to fair game Armstrong and their other targets, if he responded in any way to CSI's, Scientology's, Miscavige's and the beneficiaries' continuing to use the law to harass and destroy utterly Armstrong and their other targets, or if he responded in any way to CSI's, Scientology's, Miscavige's and the beneficiaries' rewriting of their histories. Armstrong admits that he and CSI, plus Scientology, Miscavige and the beneficiaries exchanged mutual, general releases. Armstrong denies that in consideration for a settlement payment of $800,000 he and CSI, Scientology, Miscavige and the beneficiaries exchanged mutual, general releases. Armstrong admits that paragraph 7D of the mutual release contains the following:

"Plaintiff agrees never to create or publish, or attempt to publish, and/orassist another to create for publication by means of magazine, article, bookor other similar form, any writing or broadcast or to assist another to create write, film, or video tape or audio tape any show, program or movie, or to grant interviews or discuss with others, concerning their experiences with the Church of Scientology, or concerning their personal or indirectly acquired knowledge or information concerning the Church of Scientology, L. Ron Hubbard or any of the organizations, individuals and entities listed in Paragraph 1 above. Plaintiff further agrees that he will maintain strict confidentiality and silence with respect to his experiences with the Church of Scientology and any knowledge or information he may have concerning the Church of Scientology, L. Ron Hubbard, or any of the organizations, individuals or entities listed in Paragraph 1 above.... Plaintiff agrees that if the terms of this paragraph are breached by him, that CSI and the other Releasees would be entitled to liquidated damages in the amount of $50,000 for each such breach."

Armstrong denies that in consideration for a settlement payment of $800,000 he made the covenant quoted above from paragraph 7D of the mutual release. Armstrong never agreed to any such "covenant" because it is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane. Armstrong signed the mutual release containing said illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane "covenant" because of threats from CSI, Scientology, Miscavige and the beneficiaries to the finances, health, businesses, families, reputations, persons and lives of himself, his lawyers, his friends, and the non-Scientologist parties involved in several separate cases then pending against CSI, Scientology, Miscavige or the beneficiaries; because of fraudulent representations by CSI, Scientology, Miscavige, the beneficiaries, and Armstrong's lawyer; because of the compromise of Armstrong's lawyer by CSI, Scientology, Miscavige and the beneficiaries; and because Armstrong was guided by God to sign CSI's, Scientology's, Miscavige's and the beneficiaries' illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane mutual release so that it could be shown to all the world to be exactly what it is, to wit, illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. CSI, Scientology, Miscavige, the beneficiaries and all Scientologists call all non-Scientologists "wogs," hereinafter "wogs," a Scientology hate term from the organization's "scriptures" meaning "niggers." Armstrong is a wog.

15. Armstrong denies that beginning in late 1989, he began breaching his obligations under the mutual release, including the terms of paragraph 7D. Armstrong performed all his obligations to which he had agreed as stated in the mutual release. Since the terms of paragraph 7D of the mutual release are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane, Armstrong had no obligation to perform such terms. Armstrong denies that as a result of any breaching of any of his obligations CSI, Scientology, Miscavige or the beneficiaries instituted Church of Scientology International v. Armstrong, Marin County Action No. VC 157680 against him, or any other suit against him. Armstrong denies that Church of Scientology International v. Armstrong, Marin County Action No. VC 157680 is Armstrong I. Church of Scientology International v. Armstrong, Marin County Action No. VC 157680 is Armstrong IV, hereinafter "Armstrong IV." Scientology v. Armstrong, Los Angeles Superior Court Case No. C 420153 is Armstrong I, hereinafter "Armstrong I." CSI, Scientology, Miscavige and the beneficiaries instituted Armstrong IV, Armstrong II, Armstrong III, Armstrong V, and the suit Armstrong is answering here, Armstrong VII, against Armstrong as a result of their desire to fair game him into silence using the power and authority and appearance of legality, probity and justice of the courts of California and the United States; to harass, punish and ruin Armstrong utterly for speaking the truth about CSI, Scientology, Miscavige and the beneficiaries and fair game, black PR, use of the law to harass and ruin utterly, and their other illegal and noxious policies, practices and acts; and, through CSI's, Scientology's, Miscavige's and the beneficiaries' illegal fair gaming and illegal judicial silencing, harassing, punishing and utter ruining of Armstrong, to rewrite their antisocial and criminal history which he knows and speak about. Armstrong admits that he cross-complained and that he alleged, and still alleges that CSI, plus Scientology, plus Miscavige, plus the beneficiaries had violated the mutual release. Armstrong denies that he alleged that the mutual release was void and unenforceable on a variety of grounds. Armstrong alleged and still alleges that certain conditions of the mutual release are void and unenforceable on a variety of grounds. Armstrong admits that his claims were all dismissed, but denies that they were dismissed as unfounded. Armstrong's claims were dismissed because this Court illegally and willfully abetted CSI's, Scientology's, Miscavige's and the beneficiaries' fair gaming of Armstrong, illicitly gave its power and authority to CSI, Scientology, Miscavige and the beneficiaries to harass and utterly ruin him, and improperly and legally impermissibly stripped Armstrong of his defenses and rights. Armstrong admits that a judgment was entered in favor of CSI against him for more than $500,000 in damages, interest, and costs. Armstrong admits that this Court entered a judgment of injunction against him barring breaches by him of the conditions of the mutual release which are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong denies that he conveyed away all of the assets which he had. Armstrong admits that he gave away substantial cash and a residence. Armstrong denies that he purchased the residence with the fruits of his $800,000 settlement. Armstrong denies that his settlement was $800,000. Armstrong denies that his settlement had any fruits, except for the poison apples CSI, Scientology, Miscavige and the beneficiaries planted in the "settlement." Armstrong admits that the monetary judgment CSI, Scientology, Miscavige and the beneficiaries obtained against him was discharged in bankruptcy. Armstrong denies that he proceeded to violate the injunction at will, or that he violates the injunction at will at any time. Armstrong admits that he violates the injunction, which is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, at the Will of God. Armstrong admits that this Court issued contempt orders against him on June 3, 1997 and February 11, 1998, respectively, and bench warrants with respect to those citations on August 6, 1997 and May 15, 1998. Armstrong denies that such contempt orders and warrants were the result of his violation of the injunction, since the injunction is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, but such contempt orders and warrants were the result of this Court illegally and willfully abetting CSI's, Scientology's, Miscavige's and the beneficiaries' fair gaming of Armstrong, illicitly giving its power and authority to CSI, Scientology, Miscavige and the beneficiaries to harass and utterly ruin him, and improperly and legally impermissibly stripping Armstrong of his defenses and rights. Armstrong admits that true and correct copies of said orders and bench warrants are attached to CSI's, Scientology's, Miscavige's and the beneficiaries' complaint and incorporated therein by reference as Exhibits B and C respectively. Armstrong admits he was again found in contempt by order dated July 13, 2001. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that a true and correct copy of this order is attached to CSI's, Scientology's, Miscavige's and the beneficiaries' complaint and incorporated therein by reference as Exhibit D and incorporated herein, and is therefore unable to admit or deny the same.

16. Armstrong denies that his conduct after leaving the Scientology cult in 1981 has ever been contumacious. Since this Court's injunction is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, Armstrong's violating said injunction can in no legally cognizable way be contumacious. If this Court's illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable injunction had not been illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, Armstrong's violating it could conceivably have been legally cognizable as contumacious conduct; but that is not the case. Armstrong avers yet again that he left Marin County in January, 1997 because of unceasing fair game being perpetrated against him by CSI, Scientology, Miscavige and the beneficiaries, abetted by this Court, because of continuing threats to his livelihood, reputation and life by CSI, Scientology, Miscavige and the beneficiaries, abetted by this Court, and immediately at that time because of Armstrong's discovery of a lengthy fair game PR attack on him by CSI, Scientology, Miscavige and the beneficiaries in their IRS Form 1023 Submission to the Internal Revenue on which their 1993 tax exemption is based. Armstrong also avers yet again that CSI, Scientology, Miscavige and the beneficiaries obtained their first contempt order against him from this Court, without notice to him and based on false and misleading statements, many months after he had left Marin County and relocated in British Columbia. Armstrong admits that since the February 1998 contempt order he made more than 200 oral statements and "postings" to the Internet newsgroup alt.religion.scientology, hereinafter, "a.r.s." Armstrong denies that he made any statements created and transmitted via e-mail and by "posting" to a.r.s. Armstrong admits that CSI, Scientology, Miscavige and the beneficiaries allege that any oral statements he made or statements he posted to a.r.s., or any statements created and transmitted via e-mail and by "posting" to a.r.s., should any such a thing exist, are breaches of paragraph 7D of the mutual release and the explicit terms of the injunction. Armstrong further admits that since the February 1998 contempt order he has made more than 100,000 statements, oral or written, posted to a.r.s., or not posted to a.r.s., that CSI, Scientology, Miscavige and the beneficiaries allege, will allege, or act as if they would allege, are breaches of paragraph 7D of the mutual release and the explicit terms of the injunction. Armstrong avers that the conditions of paragraph 7D of the mutual release and the explicit terms of the injunction that would prohibit him from making any of the statements he has made at any time are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that the date of each alleged breach of the more than 200 alleged breaches CSI, Scientology, Miscavige and the beneficiaries are alleging is set forth in Exhibit E to their complaint, and Armstrong is therefore unable to admit or deny the same. Armstrong denies that a short description of the substance of each alleged breach of the more than 200 alleged breaches CSI, Scientology, Miscavige and the beneficiaries are alleging is set forth in Exhibit E to their complaint. Armstrong admits that CSI, Scientology, Miscavige and the beneficiaries have incorporated Exhibit E to their complaint therein by reference as if set forth in full.

17. Armstrong admits that in December 1999 he traveled to Clearwater, Florida. Armstrong denies that his travel to Clearwater was at the invitation of Minton or the LMT. Armstrong denies that Minton and the LMT, or Minton or the LMT, paid for the expenses of his visit. Armstrong denies that Minton or the LMT did anything in connection with his visit to Clearwater in December 1999 with the purpose and intent of enabling Armstrong to violate the mutual release. Armstrong denies that Minton or the LMT did anything in connection with his visit to Clearwater in December 1999 with the purpose and intent of enabling Armstrong to make media and other public appearances as part of the LMT's anti-Scientology campaign, or not as part of the LMT's anti-Scientology campaign. Armstrong denies that the LMT had an anti-Scientology campaign. Armstrong believed and believes that the LMT had a campaign of exposing and opposing Scientology abuses and criminality, such as Scientology's fair gaming and black PRing of Armstrong and its use of the law to harass and ruin him utterly. Armstrong admits that while in Clearwater he appeared at and addressed a gathering. Armstrong denies that the gathering was assembled and sponsored by the LMT. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that the LMT produced a videotape of his remarks to the gathering in Clearwater in 1999, and is therefore unable to admit or deny the same. Armstrong denies that he began his videotaped remarks by acknowledging that his address was prohibited by the injunction because he was so brazen. Armstrong began his videotaped remarks by acknowledging that his address was prohibited by the injunction because the injunction is so illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, because Armstrong was utterly certain of that fact, and because he wanted to give any Scientologist, or wog, who might believe that such an injunction, which prohibited a person from mentioning a religion or talking about his religious experiences, was not illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, the opportunity to leave the gathering.

18. Armstrong denies that he appeared on Radio Station WMNF-AM in Tampa, Florida while still in Florida. Armstrong denies that he was in Florida on December 10, 1999. Armstrong denies that he appeared on Radio Station WMNF-AM in Tampa, Florida at the request or expense of Minton or the LMT. Armstrong admits that he gave an interview to that station. Armstrong admits that whatever he said during said interview violated paragraph 7D. Armstrong avers again that the prohibitions of CSI's, Scientology's, Miscavige's and the beneficiaries' paragraph 7D of their mutual release are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable.

19. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that Minton is a self-appointed financial benefactor of persons such as Armstrong, and is therefore unable to admit or deny the same. Armstrong denies that he is devoted to destroying the Scientology religion, because he believes that irreligion, hatred and criminality, which are the attributes of the Scientology cult he opposes and seeks to reform, are not religion. Armstrong denies that persons such as him are also devoted to destroying the Scientology religion, because they too, being persons such as him, believe irreligion, hatred and criminality, which are the attributes of the Scientology cult they, being persons such as him, oppose and seek to reform, are not religion. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that Minton is the sole incorporator of the LMT, and is therefore unable to admit or deny the same. Armstrong denies that the LMT's purpose is or ever was the demise of the Scientology religion. Armstrong believes and has always believed that the LMT's purpose was to expose, oppose and seek to reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and to assist persons who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices and acts. Armstrong believed and believes that the following is a true and correct statement of the reforms the LMT sincerely sought to bring about inside Scientology and of the LMT's sincere support for religious beliefs and whatever is religious in Scientology:

The Lisa McPherson Trust started operations in Clearwater, Florida on January 6, 2000. It was formed after decades of exhaustive investigation by media and government agencies as well as firsthand accounts from hundreds of former Scientologists. For more than twenty-five years there have been outcries that the Church of Scientology abandon its abusive and deceptive practices. But until now, there has been no formal organization committed to stopping these abuses. The Lisa McPherson Trust was established for that purpose, and we continue to demand that the Church of Scientology make the following reforms: __Tell their members and the public the truth about the life of Scientology founder L. Ron Hubbard. __Tell their members and the public the truth about the history of Dianetics and Scientology. __Cease all illegal, unethical and harassing activities against their own members and those who criticize or disagree with Scientology. __Revoke the policies and practices that violate the civil and human rights of Scientologists and those who criticize or disagree with Scientology. __Revoke the policy of practicing medicine without a license and preventing people from receiving proper medical treatment. __Stop using and abusing the legal system as a means of harassment. __Stop keeping the technology of Scientology secret if it truly has the power to help the human race. __Encourage Scientologists to speak freely among themselves. Urge them to communicate with family and friends, even those who may disagree with Scientology. End the practice of "disconnection." __Revoke the policy and practice of using private and personal material from confidential counseling sessions to blackmail, harass and intimidate. __Stop using duress to extract exorbitant sums of money from their members. The Lisa McPherson Trust firmly believes in religious freedom for all. But we do not believe that anyone has the right to engage in behavior that violates other people's rights or the laws of the land. Scientologists have every right to participate in the world's religious community in practicing their sincerely held religious beliefs. However, Scientology needs to cease its abusive and deceptive practices."

Armstrong denies that Minton's offer of $360,000 to achieve the revocation of the tax-exempt status of Scientology and its components was a manifestation of Minton's commitment to harm and act against the Scientology religion. Armstrong believed and believes that Minton's offer of $360,000 to achieve the revocation of the tax-exempt status of Scientology and its components was a manifestation of Minton's commitment to expose and oppose Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts and assist those persons who have been victimized or targeted by such irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Scientology obtained its tax exemption in 1993 by fraud, threat and other irreligious, dangerous, destructive, abusive or criminal activities, including by the fair gaming and black PRing of Armstrong personally. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that Minton made any offer in March of 1996, and is therefore unable to admit or deny the same. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that in approximately March of 1996, Minton also gave substantial sums to California residents Grady Ward, hereinafter "Ward," and Keith Henson, hereinafter "Henson," and is therefore unable to admit or deny the same. Armstrong admits that Ward and Henson were defendants in copyright actions brought by Scientology. Armstrong denies that the actions Scientology brought against Ward and Henson were to protect Scientology's intellectual property rights, but were to illegally harass, punish and ruin Ward and Henson utterly using the power and authority and appearance of legality, probity and justice of the U.S. Justice system, and thus silence Ward and Henson about, and prevent them from exposing and speaking the truth about, CSI, Scientology, Miscavige and the beneficiaries and fair game, black PR, use of the law to harass and ruin utterly, and their other illegal and noxious policies, practices and acts.

20. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that in late 1997, Minton became a director of FACTNet, and is therefore unable to admit or deny the same. Armstrong admits that FACTNet is a corporation. Armstrong denies that FACTNet's purpose is to maintain a library of negative and misleading, often utterly false, materials regarding the Church of Scientology. Armstrong believes and has always believed that FACTNet's purpose is to be, inter alia, a library and research resource which maintains and makes publicly available truthful materials about Scientology, which materials Scientology and its management willfully and cruelly hide from and deny to Scientologists, and wogs, and attempt to destroy, particularly truthful materials about Scientology's irreligious, dangerous, destructive, abusive or criminal policies and practices, such as fair game, black PR and using the law to harass and ruin utterly Scientology's fair game targets. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that in 1999 Minton resigned as a director of FACTNet and in November of that year formed the LMT, and Armstrong is therefore unable to admit or deny the same.

21. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averments that Minton was first given notice or ever given notice of the mutual release and its terms by letter dated January 14, 1998, by letter of any other date, or by any other means, on that date or any other date, from counsel for CSI, or from any other person or entity, which enclosed or did not enclose a copy of the permanent injunction issued against Armstrong ""and those acting in concert"" with him, and Armstrong is therefore unable to admit or deny the same. Armstrong avers that the injunction and the terms of the mutual release that the injunction purports to enforce are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable as to Armstrong, and are no less illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable as to anyone, Scientologist or wog alike, "acting in concert" with Armstrong, or not "acting in concert" with him.

22. Armstrong denies that CSI, Scientology, Miscavige or the beneficiaries fully ascertained facts in the summer of 2000 upon which CSI, Scientology, Miscavige and the beneficiaries make their averments contained in this paragraph. Armstrong admits that in January 1998 Minton loaned Armstrong $90,000. Armstrong denies there was any secret agreement between him and Minton regarding $25,000, or any of the $90,000. Armstrong denies that Minton gave or loaned him any money whatsoever for the specific purpose, or unspecific purpose, of financing Armstrong's breaches of paragraph 7D of the mutual release. Minton loaned money to Armstrong pursuant to Minton's public offer of a monetary reward for the revocation of CSI's, Scientology's, Miscavige's and the beneficiaries' IRS tax exemption, which was obtained by CSI, Scientology, Miscavige and the beneficiaries by illegal means, including fraud involving the filing of black PR and false statements about Armstrong. Armstrong's efforts to have CSI's, Scientology's, and the beneficiaries' IRS tax exemption revoked, since such tax exemption was obtained by CSI, Scientology, Miscavige and the beneficiaries by illegal means, including fraud involving the filing of black PR and false statements about Armstrong, and Armstrong's efforts in communicating in any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies, practices or acts of CSI, Scientology, Miscavige and the beneficiaries which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, cannot be legally prohibited, and the terms of paragraph 7D of CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release that prohibit such efforts and communications by Armstrong, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong believed and believes that Minton believed and believes that Armstrong's efforts to have CSI's, Scientology's, and the beneficiaries' IRS tax exemption revoked, since such tax exemption was obtained by CSI, Scientology, Miscavige and the beneficiaries by illegal means, including fraud involving the filing of black PR and false statements about Armstrong, and Armstrong's efforts in communicating in any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, cannot be legally prohibited, and the terms of paragraph 7D of CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release that prohibit such efforts and communications by Armstrong, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable.

23. Armstrong admits that in or about December 1999, when the LMT was formed, Minton invited him to become a member of the LMT's "Advisory Committee," hereinafter the "LMT Advisory Committee." Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that Minton possessed the knowledge that Armstrong's participation in the LMT Advisory Committee would of necessity involve a violation of the mutual release, and is therefore unable to admit or deny the same. Armstrong admits that he had the knowledge that his participation in the LMT Advisory Committee would of necessity involve a violation of the mutual release. Armstrong believed, believes and avers that any of the terms of the mutual release that Armstrong's participation in the LMT Advisory Committee would of necessity violate are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong believed and believes that Minton too believed and believes that any terms of the mutual release which Armstrong's participation in the LMT Advisory Committee would of necessity violate are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong admits that he served on the LMT Advisory Committee continuously through 2001. Armstrong denies that he and Minton, or he and the LMT, or he and Minton and the LMT, or he and anyone formed or were involved in any way in any conspiracy whatsoever as CSI, Scientology, Miscavige and the beneficiaries just allege. Armstrong avers that because no such conspiracy ever existed as CSI, Scientology, Miscavige and the beneficiaries just allege, nothing Armstrong or Minton or the LMT furthered one or could possibly further one. Armstrong denies that the LMT possessed an anti-Scientology agenda. Armstrong believed and believes that the LMT's agenda was to expose, oppose and seek to reform attributes or policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and to assist persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Armstrong believed and believes that the agenda of CSI, Scientology, Miscavige and the beneficiaries, since their agenda is irreligious, dangerous, destructive, abusive and criminal, is an anti-Scientology agenda because it puts Scientology and Scientologists at immediate and extreme risk. Armstrong admits that he promoted the LMT's agenda of exposing, opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Armstrong admits that he promoted through Internet postings as well as media and other public appearances the LMT's agenda of exposing, opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, but Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that through hundreds of Internet postings he promoted the LMT's agenda, and is therefore unable to admit or deny the same. The LMT's agenda of exposing, opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts is also Armstrong's agenda, and he has made thousands of Internet postings as well as media and other public appearances promoting that agenda. Armstrong denies that the LMT was Minton's alter ego. Armstrong denies that either Minton or the LMT was aware that Armstrong's primary means for violating paragraph 7D of the mutual release was by e-mail and postings to a.r.s. Armstrong's primary means for communicating about exposing, opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts is by speaking. Armstrong has been exposing, opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts by speaking from at least 1980. Armstrong's secondary means for communicating about exposing, opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts is by non-electronic writing. Armstrong has been exposing, opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts by non-electronic writing from at least 1980. Armstrong has only been exposing, opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts by e-mail or postings to a.r.s., his tertiary communication means for exposing, opposing and seeking to reform attributes, policies or practices of Scientology which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, since l997. Any terms of paragraph 7D of the mutual release which Armstrong violated or violates by speaking or writing, non-electronically or electronically, or by any other means or medium, in exposing, opposing and seeking to reform attributes, policies or practices of Scientology or CSI or Miscavige or the beneficiaries which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by Scientology's irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong admits that in or about December of 1999, Minton purchased a computer for Armstrong. Armstrong denies that the LMT purchased a computer for him. Armstrong denies that the LMT is Minton's alter ego. Armstrong denies that Minton purchased a computer for him for the specific purpose of using it to make publications of writings about CSI and other beneficiaries of the mutual release in violation of that mutual release and in furtherance of the conspiratorial scheme CSI, Scientology, Miscavige and the beneficiaries have just alleged in their complaint. Armstrong denies that the conspiratorial scheme CSI, Scientology, Miscavige and the beneficiaries have just alleged in their complaint exists or has ever existed. Armstrong denies that Minton purchased a computer for him for the specific purpose of using it to make publications of writings of any kind about anyone or anything. Armstrong admits that virtually any personal computer can be used to make publications of writings of any kind about anyone or anything. Armstrong denies that he has ever testified in any proceeding that Minton knew at the time that the computer would be used in the fashion CSI, Scientology, Miscavige and the beneficiaries have just alleged in their complaint. Armstrong denies that Minton knew at the time that the computer would be used in the fashion CSI, Scientology, Miscavige and the beneficiaries have just alleged in their complaint. Armstrong denies that the computer would ever be used, was ever used, is being used or will ever be used in the fashion CSI, Scientology, Miscavige and the beneficiaries have just alleged in their complaint. Armstrong denies that he has ever testified in any proceeding that Minton gave the computer to Armstrong for exactly the purpose CSI, Scientology, Miscavige and the beneficiaries have just alleged in their complaint. Armstrong denies that Minton gave the computer to Armstrong for exactly the purpose CSI, Scientology, Miscavige and the beneficiaries have just alleged in their complaint. Armstrong denies that the computer was ever used, is being used or will ever be used for exactly the purpose CSI, Scientology, Miscavige and the beneficiaries have just alleged in their complaint. Armstrong denies that he has ever testified in any proceeding that Minton knew he was giving the computer to Armstrong for any unlawful purpose whatsoever. Armstrong denies that Minton gave the computer to Armstrong for any unlawful purpose whatsoever. Armstrong denies that the computer was ever used, is being used or will ever be used for any unlawful purpose whatsoever. Armstrong denies that using the computer, or any computer, to make publications of writings about CSI and other beneficiaries, or about Scientology, or about Miscavige, or about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes or policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, is an unlawful purpose. Armstrong denies that violating terms of the mutual release which are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, such as paragraph 7D of the mutual release, is in any way whatsoever unlawful.

24. Armstrong admits that in June 2000 he traveled to Germany to attend a public ceremony where Minton was presented with an award. Armstrong denies that Minton was presented an award for any anti-Scientology activities. Minton was presented an award at a public ceremony in Germany for his contributions in exposing, opposing and seeking to reform attributes or policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Armstrong denies that exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts constitutes any anti-Scientology activity, unless Scientology is only a completely irreligious, completely dangerous, completely destructive, completely abusive and completely criminal enterprise containing only completely irreligious, completely dangerous, completely destructive, completely abusive, completely criminal and completely irredeemable policies, practices, acts and personnel. Armstrong denies that Scientology is only a completely irreligious, completely dangerous, completely destructive, completely abusive and completely criminal enterprise containing only completely irreligious, completely dangerous, completely destructive, completely abusive, completely criminal and completely irredeemable policies, practices, acts and personnel. Armstrong denies that Minton was presented the award in Europe in 2000 by a small group of like-minded extremists. Armstrong denies that Minton is an extremist. Armstrong denies that he is an extremist. Armstrong denies that any member of the group which presented the award to Minton is an extremist. The group which presented the award to Minton is the European-American Citizens Committee for Human Rights and Religious Freedom in the USA, hereinafter, the "Committee." Armstrong is a member of the Committee. Armstrong admits that Minton and the Committee have been to a degree like-minded in their dedication to exposing, opposing and seeking to reform attributes or policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Armstrong admits that during this trip he met with media representatives and communicated about CSI, Scientology, Miscavige or the beneficiaries and about exposing, opposing and seeking to reform their attributes or policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Armstrong admits that communicating about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes or policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts is a breach of certain terms of the mutual release. Armstrong believed, believes, and again avers that any terms of the mutual release which prohibit him or anyone from communicating about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes or policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong admits that these travels were in part financed and supported by Minton. Armstrong denies that these travels were financed in any part by the LMT. Armstrong denies that the LMT is or was Minton's alter ego. Armstrong denies that either Minton or the LMT financed Armstrong's meeting with any media representatives or financed Armstrong's engaging in any of his actions of communicating about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute breaches of the mutual release. Armstrong denies that Minton possessed the knowledge at any time that Armstrong would meet with media representatives and engage in actions of communicating about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes or policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute breaches of the mutual release; or that Minton possessed the knowledge at any time that Armstrong would use this or any other opportunity to further communicate about CSI, Scientology, Miscavige or the beneficiaries or exposing, opposing or seeking to reform their attributes or policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, or in any other way violate the mutual release. Armstrong admits that Minton and the LMT supported his exposing, opposing and seeking to reform CSI's, Scientology's, Miscavige's and the beneficiaries' attributes, policies and practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts.

25. Armstrong denies that from May through July of 2001 he traveled to Russia, Germany, Denmark, the United Kingdom and other countries. Armstrong admits that from April to June 2001 he traveled to Russia, Germany, Denmark, the United Kingdom and other countries. Armstrong admits that during the period of May to July 2001 he met with media personnel and made numerous public statements about CSI, Scientology, Miscavige or the beneficiaries and about exposing, opposing and seeking to reform their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Armstrong admits that making public statements about CSI, Scientology, Miscavige or the beneficiaries and about exposing, opposing and seeking to reform their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, is a violation of certain terms of the mutual release. Armstrong believed, believes, and again avers that any terms of the mutual release that prohibit him or anyone from making public statements about CSI, Scientology, Miscavige or the beneficiaries and exposing, opposing and seeking to reform their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong admits that his travels during April, May and June 2001 were in part financed and supported by Minton. Armstrong denies that these travels were financed in any part by the LMT. Armstrong denies that the LMT is or was Minton's alter ego. Armstrong denies that either Minton or the LMT financed any of Armstrong's actions of meeting with any media personnel or of making any public statements about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes or policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute violations of the mutual release. Armstrong denies that Minton possessed the knowledge at any time that Armstrong would meet with media personnel and make numerous or any public statements about CSI, Scientology, Miscavige or the beneficiaries and about exposing, opposing and seeking to reform their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute breaches of the mutual release; or that Minton possessed the knowledge at any time that Armstrong would use this or any other opportunity to make numerous or any public appearances where such statements about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, occurred. Armstrong admits that he was in Leipzig, Germany and publicly appeared with Minton, Stacy, and other LMT employees. Armstrong admits that in Leipzig he made public statements about CSI, Scientology, Miscavige and the beneficiaries and about exposing, opposing and seeking to reform their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, and that such public statements violate certain terms of the mutual release. Armstrong denies that Minton possessed the knowledge at any time that Armstrong would make the public statements Armstrong made or that Armstrong would make any public statements in Leipzig about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute violations of the mutual release. Any terms of the mutual release that prohibit Armstrong, anyone acting in concert with him, or anyone else, from making the public appearances and public statements that Armstrong made in Leipzig, or anywhere else in Europe, or anywhere else in the world, about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes, policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute violations of the mutual release, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong believed and believes that Minton too believed and believes that the terms of the mutual release that prohibit Armstrong, anyone acting in concert with him, or anyone else, from making the public appearances and public statements that Armstrong made in Leipzig, anywhere else in Europe, or anywhere else in the world, about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes or policies or practices which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute violations of the mutual release, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong admits that Minton and the LMT supported Armstrong's exposing, opposing and seeking to reform CSI's, Scientology's, Miscavige's and the beneficiaries' attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Armstrong admits that although Minton encouraged Armstrong's exposing, opposing and seeking to reform CSI's, Scientology's, Miscavige's and the beneficiaries' attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, at no time did Minton encourage Armstrong in any violations of the mutual release. Armstrong repeats that he believed and believes that Minton too believed and believes that the terms of the mutual release that prohibit Armstrong, anyone acting in concert with him, or anyone else from making public statements about CSI, Scientology, Miscavige or the beneficiaries or about exposing, opposing and seeking to reform their attributes or policies or practices that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, which CSI, Scientology, Miscavige and the beneficiaries are alleging constitute violations of the mutual release, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable.

FIRST CAUSE OF ACTION (Breach of Contract Alleged of Gerald Armstrong)

26. In answering the averments contained in this paragraph wherein CSI, Scientology, Miscavige and the beneficiaries incorporate by reference their averments contained in paragraphs 1 through 25, inclusive, of their complaint, Armstrong admits, denies and avers to the same effect and in the same manner as he admitted, denied and averred with respect to those specific paragraphs as previously set forth in this answer.

27. Armstrong denies that by reason of the facts alleged in paragraphs 15, 16, and 17 of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint Armstrong has committed 201 separate and distinct breaches of paragraph 7D of the mutual release. By reason of the facts alleged in paragraphs 15, 16, and 17 of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint, Armstrong has committed 204 separate and distinct breaches of paragraph 7D of the mutual release, plus more than 99,796 more separate and distinct breaches of paragraph 7D of the mutual release, for a grand total of more than 100,000 separate and distinct breaches of paragraph 7D of the mutual release. Armstrong denies that as a result of any facts alleged by CSI, Scientology, Miscavige and the beneficiaries in their complaint, or as a result of anything Armstrong has done or not done at any time, CSI, Scientology, Miscavige or the beneficiaries are entitled to liquidated damages of $50,000 for each such breach, or even that $50,000 for each such breach totals $10,050,000. By reason of the facts stated by Armstrong herein, neither CSI, Scientology, Miscavige nor any of the beneficiaries are entitled to even one red cent in liquidated damages, or damages from Armstrong of any amount or kind whatsoever.

SECOND CAUSE OF ACTION (Intentional Interference with Contractual Relations Alleged Against Robert Minton and the LMT)

28. In answering the averments contained in this paragraph wherein CSI, Scientology, Miscavige and the beneficiaries incorporate by reference their averments contained in paragraphs 1 through 25, inclusive, and paragraph 27 of their complaint, Armstrong admits, denies and avers to the same effect and in the same manner as he admitted, denied and averred with respect to those specific paragraphs as previously set forth in this answer.

29. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that by reason of the facts set forth in CSI's, Scientology's, Miscavige's and the beneficiaries' complaint, Minton and the LMT, or Minton or the LMT, has or ever had knowledge and notice of both the mutual release and the injunction, and Armstrong is therefore unable to admit or deny the same. Armstrong denies that by reason of the facts set forth in CSI's, Scientology's, Miscavige's and the beneficiaries' complaint, Minton and the LMT, or Minton or the LMT, willfully, deliberately, and maliciously aided and financially rewarded and enabled Armstrong, or willfully, or deliberately, or maliciously aided or financially rewarded or enabled Armstrong, to breach his contractual obligations, as alleged in paragraphs 15, 16, 17, and 24 of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint. The terms of the mutual release that Armstrong at any time breached by communicating in any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, and Armstrong therefore had no legally cognizable contractual obligation to not breach those terms. Armstrong believed and believes that Minton and the LMT also believed and believe that the terms of the mutual release which Armstrong at any time breached by communicating in any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, and Armstrong therefore had no legally cognizable contractual obligation to not communicate in any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries which are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Armstrong denies that the LMT made any payments to Armstrong. Armstrong denies that Minton's intention in giving or loaning any money to Armstrong was to provide Armstrong with the financial wherewithal to allow him to continue his admitted breaches of the mutual release, to reward him for his earlier breaches, and to frustrate CSI and deny it the benefits of the mutual release to which it was and is entitled. Armstrong denies that Minton's intention in giving or loaning any money to Armstrong was to provide Armstrong with the financial wherewithal to allow him to continue his admitted breaches of the mutual release, to reward him for his earlier breaches, and to frustrate CSI, or Scientology, or Miscavige, or the beneficiaries and deny any of them the benefits of the mutual release to which any of them were or are entitled. Each and every benefit of the mutual release to which CSI, or Scientology, or Miscavige, or any of the beneficiaries were or are legally entitled was received by them, and not denied to any of them at any time or in any way or manner by anything Armstrong did or did not do. Prohibiting Armstrong from communicating in any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, and is not a benefit to which either CSI, Scientology, Miscavige or any of the beneficiaries is legally entitled. Armstrong believed and believes that Minton believed and believes that prohibiting Armstrong from communicating in any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, and is not a benefit to which either CSI, Scientology, Miscavige or any of the beneficiaries is legally entitled. Minton loaned money to Armstrong pursuant to Minton's public offer of a monetary reward for the revocation of CSI's, Scientology's, Miscavige's and the beneficiaries' IRS tax exemption, which was obtained by CSI, Scientology, Miscavige and the beneficiaries by illegal means, including fraud involving the filing of black PR and false statements about Armstrong. An IRS tax exemption obtained by illegal means, including fraud involving the filing of black PR and false statements about Armstrong, or anyone, is not a benefit to which CSI, Scientology, Miscavige and the beneficiaries are legally entitled. Armstrong's efforts to have the IRS tax exemption of CSI, Scientology, Miscavige and the beneficiaries revoked, since such tax exemption was obtained by CSI, Scientology, Miscavige and the beneficiaries by illegal means, including fraud involving the filing of black PR and false statements about Armstrong, and Armstrong's efforts in communicating in any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, cannot be legally prohibited, and CSI's, Scientology's, Miscavige's and the beneficiaries' actions to attempt to prohibit such efforts and communications by Armstrong, including the terms of CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release that prohibit such efforts and communications by Armstrong, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong believed and believes that Minton believed and believes that Armstrong's efforts to have the IRS tax exemption of CSI, Scientology, Miscavige and the beneficiaries revoked, since such tax exemption was obtained by CSI, Scientology, Miscavige and the beneficiaries by illegal means, including fraud involving the filing of black PR and false statements about Armstrong, and Armstrong's efforts in communicating in any manner, form or medium about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, cannot be legally prohibited, and CSI's, Scientology's, Miscavige's and the beneficiaries' actions to attempt to prohibit such efforts and communications by Armstrong, including the terms of CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release that prohibit such efforts and communications by Armstrong, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong denies that Minton's intention in giving or loaning any money to Armstrong was to frustrate CSI, or Scientology, or Miscavige or any of the beneficiaries. Armstrong admits that his very existence frustrates CSI's, Scientology's, Miscavige's and the beneficiaries' attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, frustrates CSI's, Scientology's, Miscavige's and the beneficiaries' victimizing, fair gaming, black PRing or targeting of persons such as Armstrong, and frustrates CSI's, Scientology's, Miscavige's and the beneficiaries' efforts to rewrite their antisocial and criminal history, which Armstrong knows and speaks about. Armstrong admits that Minton's intention in giving or loaning money to Armstrong was to aid, enable and prolong his very existence. Armstrong denies that frustrating CSI's, Scientology's, Miscavige's and the beneficiaries' attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, frustrating CSI's, Scientology's, Miscavige's and the beneficiaries' victimizing, fair gaming, black PRing or targeting of persons such as Armstrong, or frustrating CSI's, Scientology's, Miscavige's and the beneficiaries' efforts to rewrite their antisocial and criminal history, which Armstrong knows and speaks about, frustrates CSI, Scientology, Miscavige or the beneficiaries. Indeed, Armstrong assists CSI, Scientology, Miscavige and the beneficiaries by frustrating what frustrates them and puts them all at risk, to wit, their attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, their victimizing, fair gaming, black PRing or targeting of persons such as Armstrong, and CSI's, Scientology's, Miscavige's and the beneficiaries' efforts to rewrite their antisocial and criminal history, which Armstrong knows and speaks about. Armstrong believed and believes that Minton believed and believes that Armstrong's very existence frustrates CSI's, Scientology's, Miscavige's and the beneficiaries' attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, frustrates CSI's, Scientology's, Miscavige's and the beneficiaries' victimizing, fair gaming, black PRing or targeting of persons such as Armstrong, and frustrates CSI's, Scientology's, Miscavige's and the beneficiaries' efforts to rewrite their antisocial and criminal history, which Armstrong knows and speaks about; that frustrating CSI's, Scientology's, Miscavige's and the beneficiaries' attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, frustrating CSI's, Scientology's, Miscavige's or the beneficiaries' victimizing, fair gaming, black PRing or targeting of persons such as Armstrong, or frustrating CSI's, Scientology's, Miscavige's and the beneficiaries' efforts to rewrite their antisocial and criminal history which, Armstrong knows and speaks about, does not frustrate CSI, Scientology, Miscavige or the beneficiaries, but indeed assists CSI, Scientology, Miscavige and the beneficiaries by frustrating what frustrates them and puts them all at risk, to wit, CSI's, Scientology's, Miscavige's and the beneficiaries' attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, CSI's, Scientology's, Miscavige's and the beneficiaries' victimizing, fair gaming, black PRing or targeting of persons such as Armstrong, and CSI's, Scientology's, Miscavige's and the beneficiaries' efforts to rewrite their antisocial and criminal history, which Armstrong knows and speaks about. Armstrong admits that in or about December 1999 Minton gave a computer to him. Armstrong denies that Minton gave him a computer as a reward for Armstrong's past breaches, or as a reward for anything else. Minton gave Armstrong a computer because Armstrong is Minton's friend, and because, on information and belief, a third party mentioned to Minton that Armstrong was using an older model computer that would not run certain applications. The applications that Armstrong's older computer would not run did not include e-mail or newsreader programs. Terms of paragraph 7D of the mutual release that prohibit Armstrong, or anyone else, from communicating about CSI, Scientology, Miscavige or the beneficiaries, about exposing, opposing and seeking to reform their attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, and about assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, by e-mail, by postings to a.r.s., by postings to any other newsgroup, or by any other means or medium, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Armstrong believed and believes that Minton believed and believes that the terms of paragraph 7D of the mutual release that prohibit Armstrong, or anyone else, from communicating about CSI, Scientology, Miscavige or the beneficiaries, about exposing, opposing and seeking to reform their attributes, policies or practices that are irreligious, dangerous, destructive, abusive or criminal, and about assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, by e-mail, by postings to a.r.s., by postings to any other newsgroup, or by any other means or medium, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Each and every benefit of the mutual release to which CSI, or Miscavige, or Scientology, or any of the beneficiaries was or is legally entitled was received by each and every one of them, and not denied to any of them at any time or in any way or manner. Armstrong denies that, because each and every benefit of the mutual release to which CSI, Scientology, Miscavige or the beneficiaries was or is legally entitled was received by them, the efforts by CSI, Scientology, Miscavige or the beneficiaries to obtain said benefits are or were at any time frustrated in any way, manner or degree whatsoever by Minton's giving Armstrong a computer, or by anything Armstrong communicated by e-mail, by posting to a.r.s., or by posting to any other newsgroup, using said computer, or by Armstrong's communicating anything he communicated at any time by any other means or medium. Prohibiting Armstrong, anyone acting in concert with him, or anyone else, from communicating by e-mail, by postings to a.r.s., by postings to any other newsgroup, or by any other means or medium in any manner, form or medium, about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige or the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's or the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, and is not a benefit to which either CSI, Scientology, Miscavige or any of the beneficiaries is legally entitled. Armstrong believed and believes that Minton believed and believes that prohibiting Armstrong, anyone acting in concert with him, or anyone else, from communicating by e-mail, by postings to a.r.s., by postings to any other newsgroup, or by any other means or medium, about CSI, Scientology, Miscavige or the beneficiaries, about Armstrong's experiences in relation to any of these persons or entities, or about exposing, opposing and seeking to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and assisting persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, is illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, and is not a benefit to which either CSI, Scientology, Miscavige or any of the beneficiaries is legally entitled.

30. Armstrong denies that as a direct and proximate result of the conduct of Minton and the LMT as alleged in CSI's complaint CSI has been damaged in an amount in excess of the jurisdictional minimum of this Court. Armstrong denies that as a direct and proximate result of the conduct of Minton and the LMT as alleged in CSI's, Scientology's, Miscavige's, or the beneficiaries' complaint either CSI, or Scientology, or Miscavige, or any of the beneficiaries has been damaged in an amount in excess of the jurisdictional minimum of this Court. Armstrong denies that as a direct and proximate result of the conduct of Minton and the LMT as alleged in CSI's, Scientology's, Miscavige's and the beneficiaries' complaint either CSI, or Scientology, or Miscavige, or any of the beneficiaries has been damaged in any amount, way or manner whatsoever. Armstrong admits that the exact amount by which CSI, or Scientology, or Miscavige or any of the beneficiaries has been damaged in excess of the jurisdictional minimum of this Court, as a direct and proximate result of the conduct of Minton and the LMT, or Minton or the LMT, as alleged in CSI's, Scientology's, Miscavige's, and the beneficiaries' complaint, will be proven at trial, to wit, not a whit. The exact amount by which CSI, or Scientology, or Miscavige, or any of the beneficiaries has been damaged in any way or manner whatsoever as a direct and proximate result of the conduct of Minton and the LMT as alleged in CSI's, Scientology's, Miscavige's and the beneficiaries' complaint, will also be proven at trial, to wit, not one thin dime.

31. Armstrong denies that Minton and the LMT, or Minton or the LMT, harbors actual ill will and malice, or actual ill will or malice, toward CSI, or toward Scientology, Miscavige or any of the beneficiaries. Minton and the LMT harbor and extend good will and benevolence toward CSI, Scientology, Miscavige and the beneficiaries, as demonstrated by Minton's and the LMT's agenda, campaign and efforts to expose, oppose and seek to reform attributes or policies or practices of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and to assist persons such as Armstrong, including CSI's, Scientology's, Miscavige's and the beneficiaries' own personnel, who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, despite Minton and the LMT being themselves victimized and targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies or practices, including but not limited to fair game, Black PR and using the law to harass and ruin utterly. Armstrong denies that Minton and the LMT, or Minton or the LMT, interfered in any way with CSI's, or Scientology's or Miscavige's or any of the beneficiaries' enjoyment of the benefits to which any of them was or is entitled under the mutual release. Each and every benefit of the mutual release to which CSI, or Scientology, or Miscavige, or any of the beneficiaries was or is legally entitled was received by them, and not denied to any of them at any time or in any way or manner by Minton, the LMT or Armstrong, or anything Minton, the LMT or Armstrong did or did not do. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that CSI, or Scientology, or Miscavige, or any of the beneficiaries did not enjoy the benefits to which any of them was or is entitled under the mutual release, and which they received and were not denied at any time or in any way or manner by Minton, the LMT or Armstrong, or by anything Minton, the LMT or Armstrong did or did not do, and Armstrong is therefore unable to admit or deny the same. Armstrong denies that Minton and the LMT, or Minton or the LMT, did anything that CSI, Scientology, Miscavige or any of the beneficiaries allege in their complaint interfered in any way with CSI's, Scientology's, or Miscavige's or any of the beneficiaries' enjoyment of the benefits to which any of them was or is entitled under the mutual release as part of Minton's and the LMT's, or Minton's or the LMT's, avowed plan to destroy the Scientology religion. Armstrong denies that Minton and the LMT, or Minton or the LMT, had an avowed plan to destroy the Scientology religion. Armstrong denies that Minton and the LMT, or Minton or the LMT, had any plan, avowed or not avowed, to destroy the Scientology religion. Minton and the LMT had a plan to expose, oppose and seek to reform attributes or policies or practices of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and to assist persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts. Armstrong denies that such a plan as Minton's and the LMT's plan to expose, oppose and seek to reform attributes, policies or practices of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and to assist persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, is a plan to destroy the Scientology religion. Such a plan as Minton's and the LMT's plan to expose, oppose and seek to reform attributes, policies, practices or acts of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive or criminal, and to assist persons such as Armstrong who have been victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive or criminal policies, practices or acts, is a plan to save whatever of Scientology is not irreligious, not dangerous, not destructive, not abusive and not criminal from being destroyed as a result of the attributes, policies, practices or acts of CSI, Scientology, Miscavige and the beneficiaries that are irreligious, dangerous, destructive, abusive and criminal, and to save Scientologists, as well as wogs such as Armstrong, from being victimized or targeted by CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive and criminal policies, practices or acts. Armstrong denies that any conduct of Minton or the LMT alleged in CSI's, Scientology's, Miscavige's and the beneficiaries' complaint is willful, malicious or despicable in any way whatsoever. Armstrong denies that any conduct of Minton or the LMT alleged in CSI's, Scientology's, Miscavige's and the beneficiaries' complaint justifies an award of punitive damages, or an award of any other kind or type of damages, against Minton or the LMT, or against any other person or entity, in any amount whatsoever. Armstrong admits that an award of punitive damages, or of any other kind or type of damages, against Minton or the LMT, or against any other person or entity, will be in accordance with proof, to wit, zip.

THIRD CAUSE OF ACTION (Conspiracy to Breach Contract And To Interfere With Contractual Relations Against Gerald Armstrong, Robert Minton and LMT)

32. In answering the averments contained in this paragraph wherein CSI, Scientology, Miscavige and the beneficiaries incorporate by reference their averments contained in paragraphs 1 through 25, Armstrong admits, denies and avers to the same effect and in the same manner as he admitted, denied and averred with respect to those specific paragraphs as previously set forth in this answer.

33. Armstrong denies that as alleged in the first and second causes of action of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint Defendants Minton, the LMT or Armstrong agreed and knowingly and willfully conspired, or agreed or knowingly or willfully conspired, between themselves, or between or with anyone else, to enable Armstrong to breach his contractual obligations between CSI, Scientology, Miscavige and the beneficiaries and Armstrong. Armstrong performed perfectly all his contractual obligations to CSI, Scientology, Miscavige or the beneficiaries. What CSI, Scientology, Miscavige and the beneficiaries are alleging in their complaint are terms of contractual obligations between Armstrong and CSI, Scientology, Miscavige and the beneficiaries that Armstrong breached are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, and therefore do not and cannot constitute legally cognizable contractual obligations. Armstrong believed and believes that Minton believed and believes that what CSI, Scientology, Miscavige and the beneficiaries are alleging in their complaint are terms of contractual obligations between Armstrong and CSI, Scientology, Miscavige and the beneficiaries that Armstrong breached are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, and therefore do not and cannot constitute legally cognizable contractual obligations. Armstrong denies that Defendants Minton, the LMT or Armstrong agreed and knowingly and willfully conspired, between themselves, or between or with anyone else, to do or not do anything whatsoever. Armstrong denies that as alleged in the first and second causes of action of CSI's, Scientology's, Miscavige's and the beneficiaries' complaint Defendants Minton, the LMT, Armstrong or anyone else deliberately interfered, undeliberately interfered, or interfered in any way or manner whatsoever, with the contractual relations between CSI, Scientology, Miscavige or any of the beneficiaries and Armstrong. Armstrong performed perfectly all his obligations in his contractual relations with CSI, Scientology, Miscavige or and the beneficiaries. What CSI, Scientology, Miscavige and the beneficiaries are alleging in their complaint are terms in the contractual relations between Armstrong and CSI, Scientology, Miscavige and the beneficiaries with which Defendants Minton, the LMT or Armstrong interfered, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, do not and cannot constitute legally cognizable contractual terms, and therefore may be legally interfered with as Defendants Minton, the LMT or Armstrong legally interfered with them. Armstrong believed and believes that Minton believed and believes that what CSI, Scientology, Miscavige and the beneficiaries are alleging in their complaint are terms in the contractual relations between Armstrong and CSI, Scientology, Miscavige and the beneficiaries with which Defendants Minton, the LMT or Armstrong interfered, are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, do not and cannot constitute legally cognizable contractual terms, and therefore may be legally interfered with as Defendants Minton, the LMT or Armstrong legally interfered with them. Armstrong denies that Defendants, Minton, or the LMT, or Armstrong, or anyone else, did the acts and things that CSI, Scientology, Miscavige and the beneficiaries have just alleged in their complaint pursuant to, and in furtherance of, the conspiracy and agreement between Defendants, Minton, and the LMT, and Armstrong, and anyone else, or Minton, or the LMT, or Armstrong, or anyone else, that CSI, Scientology, Miscavige and the beneficiaries have alleged in their complaint. Armstrong denies that there exists or has ever existed the conspiracy and agreement, or the conspiracy or agreement, between Defendants, Minton, or the LMT, or Armstrong, or anyone else, that CSI, Scientology, Miscavige and the beneficiaries have just alleged in their complaint.

34. Armstrong denies that as a proximate result of the wrongful acts alleged by CSI, Scientology, Miscavige and the beneficiaries in their complaint any of them has been generally damaged, specifically damaged, or damaged in any amount, way or manner whatsoever. Armstrong denies that any of the acts of Armstrong, Minton, the LMT, Does 1 through 50, or anyone else, alleged by CSI, Scientology, Miscavige and the beneficiaries in their complaint and labeled by them as wrongful, are in fact and in truth wrongful in any way or manner whatsoever. Armstrong admits that the sum in which CSI, Scientology, Miscavige and the beneficiaries have been generally damaged, specifically damaged, or damaged in any amount, way or manner whatsoever, by any or all of the acts of Armstrong, Minton, the LMT, Does 1 through 50, or anyone else, alleged in CSI's, Scientology's, Miscavige's and the beneficiaries' complaint will be proven at trial, to wit, not one dinky Deutsch Mark, hereinafter, "DM."

35. Armstrong lacks knowledge or information sufficient to form a belief as to the truth of the averment that at all times alleged by CSI, Scientology, Miscavige and the beneficiaries in their complaint, or at any time, Defendants Minton or the LMT knew of the provisions of CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release with Armstrong, and Armstrong is therefore unable to admit or deny the same. Armstrong admits that at all times alleged by CSI, Scientology, Miscavige and the beneficiaries in their complaint Armstrong knew of the provisions of CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release with Armstrong. Armstrong admits that Armstrong, Minton and the LMT did the things they did, whether alleged or not alleged by CSI, Scientology, Miscavige and the beneficiaries in their complaint, intentionally. Armstrong denies that Armstrong, Minton or the LMT did any of the things alleged by CSI, Scientology, Miscavige and the beneficiaries in their complaint, if Armstrong, Minton and the LMT actually did do any of those things, willfully, fraudulently, and maliciously, or willfully, fraudulently, or maliciously. Armstrong denies that Armstrong, Minton or the LMT did any of the things alleged by CSI, Scientology, Miscavige and the beneficiaries in their complaint, if Armstrong, Minton and the LMT actually did do any of those things, to defraud and oppress, or defraud or oppress, CSI, Scientology, Miscavige or the beneficiaries. Armstrong, Minton and the LMT did the things alleged by CSI, Scientology, Miscavige and the beneficiaries in their complaint, if Armstrong, Minton and the LMT actually did do any of those things, to expose, oppose and reform the fraud and oppression by CSI, Scientology, Miscavige and the beneficiaries. Armstrong denies that CSI, Scientology, Miscavige or the beneficiaries are entitled to exemplary or punitive damages in the sum of One Million Dollars ($1,000,000). Armstrong denies that CSI, Scientology, Miscavige or the beneficiaries are entitled to exemplary or punitive damages of even one DM.

FIRST AFFIRMATIVE DEFENSE (Failure To State A Cause Of Action)

36. Further answering said complaint, and as a first, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 35 and 37 through 79 herein and alleges as follows: The complaint and each cause of action contained therein fails to state a cause of action against Armstrong, or against Minton or the LMT, upon which relief can be granted.

SECOND AFFIRMATIVE DEFENSE (Unclean Hands)

37. Further answering said complaint, and as a second, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 36 and 38 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing their action against Armstrong, Minton or the LMT and/or obtaining the equitable relief requested therein under the doctrine of unclean hands, because CSI, Scientology, Miscavige and the beneficiaries have subjected Armstrong, Minton and the LMT to CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive and criminal policies and practices, including fair game, Black PR and using the law to harass and ruin utterly. CSI, Scientology, Miscavige and the beneficiaries have themselves breached the mutual release that they seek to enforce against Armstrong, Minton and the LMT. Through their relentless fair gaming, black PRing and using the law to harass and utterly ruin Armstrong for more than twenty years, CSI, Scientology, Miscavige and the beneficiaries have themselves created a condition and circumstances wherein it is impossible for Armstrong to not "breach" the terms of the mutual release and the injunction CSI, Scientology, Miscavige and the beneficiaries seek to enforce against him, in order to defend himself against their irreligious, dangerous, destructive, abusive and criminal attacks. CSI, Scientology, Miscavige and the beneficiaries have employed the mutual release to suppress evidence of their criminal and civil wrongdoing in order to avoid liability to Armstrong, to Minton and the LMT, and to other individuals and entities whom CSI, Scientology, Miscavige and the beneficiaries have subjected to their now decades of irreligious, dangerous, destructive, abusive and criminal policies practices and acts, including fair game, Black PR and using the law to harass and ruin utterly.

THIRD AFFIRMATIVE DEFENSE (In Pari Delicto)

38. Further answering said complaint, and as a third, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 37 and 39 through 79 herein and alleges as follows: Notwithstanding the things alleged of Armstrong, Minton or the LMT in the complaint which are denied in the applicable paragraphs herein, CSI's, Scientology's, Miscavige's and the beneficiaries' and their counsels' conduct in connection with the events giving rise to this action bars any and all of them from recovery with regard to the complaint under the doctrine of pari delicto.

FOURTH AFFIRMATIVE DEFENSE (Illegality)

39. Further answering said complaint, and as a fourth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 38 and 40 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action as a result of their acts of illegality in connection with matters that give rise to this case. CSI, Scientology, Miscavige and the beneficiaries engaged in and are engaging in a wholesale attempt to suppress evidence and obstruct justice in order to deny redress, due process, and equal protection of the law to their civil and criminal victims by means of contracts, settlement agreements or mutual releases required of their adversaries in actions in various state and federal courts across the United States, and by means of CSI's, Scientology's, Miscavige's and the beneficiaries' dishonest, abusive, malicious and illegal efforts to judicially enforce such contracts, settlement agreements or mutual releases, as they are doing here against Armstrong, Minton and the LMT. Michael J. Flynn, hereinafter "Flynn," attorney for Armstrong in Armstrong I, the litigation the mutual release at issue herein purported to settle, was attorney of record or coordinating counsel for a number of these victims, fair game targets, claimants or litigants adverse to Scientology. In each of those actions, victims, fair game targets, claimants or litigants adverse to Scientology were coerced and/or tricked into signing secret settlement agreements, the terms of which were substantially similar to those set forth in the mutual release at issue herein. CSI, Scientology, Miscavige and the beneficiaries are further barred from bringing this action because the mutual release, in addition to being constructed and intended for an illegal purpose, specifically the suppression of evidence and the obstruction of justice in order to deny redress, due process, and equal protection of the law to CSI's, Scientology's, Miscavige's and the beneficiaries' civil and criminal victims and adversaries in actions in state and federal courts across the United States, and courts around the world, contains terms which on their face are illegal, including, but not limited to, the following paragraphs:

7D. Plaintiff agrees never to create or publish or attempt to publish, and/or assist another to create for publication by means of magazine, article, book or other similar form, any writing or to broadcast or to assist another to create, write, film or video tape or audio tape any show, program or movie, or to grant interviews or discuss with others, concerning their experiences with the Church of Scientology, or concerning their personal or indirectly acquired knowledge or information concerning the Church of Scientology, L. Ron Hubbard or any of the organizations, individuals and entities listed in Paragraph 1 above. Plaintiff further agrees that he will maintain strict confidentiality and silence with respect to his experiences with the Church of Scientology and any knowledge or information he may have concerning the Church of Scientology, L. Ron Hubbard, or any of the organizations, individuals and entities listed in Paragraph 1 above. Plaintiff expressly understands that the non-disclosure provisions of this subparagraph shall apply, inter alia, but not be limited, to the contents or substance of his complaint on file in the action referred to in Paragraph 1 hereinabove or any documents as defined in Appendix "A" to this Agreement, including but not limited to any tapes, films, photographs, recastings, variations or copies of any such materials which concern or relate to the religion of Scientology, L. Ron Hubbard, or any of the organizations, individuals, or entities listed in Paragraph 1 above. The attorneys for Plaintiff, subject to the ethical limitations restraining them as promulgated by the state or federal regulatory associations or agencies, agree not to disclose any of the terms and conditions of the settlement negotiations, amount of the settlement, or statements made by either party during settlement conferences. Plaintiff agrees that if the terms of this paragraph are breached by him, that CSI and the other Releasees would be entitled to liquidated damages in the amount of $50,000 for each such breach. All movies received to induce or in payment for a breach of this Agreement, or any part thereof, shall be held in a constructive trust pending the outcome of any litigation over said breach. The amount of liquidated damages herein is an estimate of the damages that each party would suffer in the event this Agreement is breached. The reasonableness of the amount of such damages, are hereto acknowledged by Plaintiff.

7F. Plaintiff agrees that he will never again seek or obtain spiritual counselling or training or any other service from any Church of Scientology, Scientologist, Dianetics or Scientology auditor, Scientology minister, Mission of Scientology, Scientology organization or Scientology affiliated organization.

7G. Plaintiff agrees that he will not voluntarily assist or cooperate with any person adverse to Scientology in any proceeding against any of the Scientology organizations, individuals, or entities listed in Paragraph 1 above. Plaintiff also agrees that he will not cooperate in any manner with any organizations aligned against Scientology.

7H. Plaintiff agrees not to testify or otherwise participate in any other judicial, administrative or legislative proceeding adverse to Scientology or any of the Scientology Churches, individuals or entities listed in Paragraph 1 above unless compelled to do so by lawful subpoena or other lawful process. Plaintiff shall not make himself amenable to service of any such subpoena in a manner which invalidates the intent of this provision. Unless required to do so by such subpoena, Plaintiff agrees not to discuss this litigation or his experiences with and knowledge of the Church with anyone other than members of his immediate family. As provided hereinafter in Paragraph 18(d), the contents of this Agreement may not be disclosed.

7L. Notwithstanding the provisions of Paragraph 7(E) above, Plaintiff shall be entitled to retain any artwork created by him which concerns or relates to the religion of Scientology, L. Ron Hubbard or any of the organizations, individuals or entities listed in Paragraph 1 above provided that such artwork never be disclosed either directly or indirectly, to anyone. In the event of a disclosure in breach of this Paragraph 7(L), Plaintiff shall be subject to the liquidated damages and constructive trust provisions of Paragraph 7(D) for each such breach.

10. Plaintiff agrees that he will not assist or advise anyone, including individuals, partnerships, associations, corporations, or governmental agencies contemplating any claim or engaged in litigation or involved in or contemplating any activity adverse to the interests of any entity or class of persons listed above in Paragraph 1 of this Agreement.

CSI, Scientology, Miscavige and the beneficiaries are further barred from bringing this action because, as a condition of settling with Flynn's clients, including Armstrong, CSI, Scientology, Miscavige and the beneficiaries required Flynn to sign secret side agreements for indemnification for resolution of the retrial of Armstrong I were CSI, Scientology, Miscavige and the beneficiaries successful in obtaining reversal of the judgment in Armstrong I on appeal. In said agreements, CSI, Scientology, Miscavige and the beneficiaries promised to limit their collections of damages to $25,001.00 and to indemnify Flynn for the payment thereof and Flynn, in turn, would indemnify Armstrong for any such judgment. The existence of these secret, side agreements was never disclosed to Armstrong by Flynn or by any of CSI, Scientology, Miscavige or the beneficiaries. CSI, Scientology, Miscavige and the beneficiaries are further barred from bringing this action because, as a condition of entering said settlement, they required attorney Flynn to promise never to represent or assist Armstrong in any way, or any other wog in any way, against CSI, Scientology, Miscavige or the beneficiaries, even if CSI, Scientology, Miscavige or any of the beneficiaries attempted to judicially enforce the mutual release. Thereafter, although Flynn has refused to provide any declaration for Armstrong in Armstrong's defenses against CSI's, Scientology's, Miscavige's and the beneficiaries' lawsuits, that is to say, Armstrong II, III, IV and V, all of which were and are intended, through the claimed lawful judicial enforcement of the mutual release, to illegally fair game Armstrong into silence, using the power and authority and the appearance of legality, probity and justice of the California and US courts, to punish Armstrong for speaking the truth about CSI, Scientology, Miscavige and the beneficiaries and about fair game, black PR, use of the law to harass and ruin utterly, and their other illegal and noxious policies, practices and acts, and, through the illegal fair gaming and illegal judicial silencing and punishing of Armstrong, and to rewrite CSI's, Scientology's, Miscavige's and the beneficiaries' antisocial and criminal history, which Armstrong knows and speak about, Flynn has been willing, after the December 1986 settlement, to provide a declaration to CSI, Scientology, Miscavige and the beneficiaries in Armstrong I, against Armstrong's wishes, to assist CSI, Scientology, Miscavige and the beneficiaries to achieve their illicit goals against their victims and fair game targets. CSI, Scientology, Miscavige and the beneficiaries are further barred from bringing this action because, before they compromised Flynn and illegally required of him as a condition of settlement of the litigations in which he represented several of CSI's, Scientology's, Miscavige's and the beneficiaries' victims or fair game targets, that he never represent or assist any person, including Armstrong, in any way against CSI, Scientology, Miscavige and the beneficiaries, even if CSI, Scientology, Miscavige or any of the beneficiaries attempted to judicially enforce the mutual release, CSI, Scientology, Miscavige and the beneficiaries subjected Flynn to seven years of their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, specifically, including, but not limited to, suing Flynn or his office or associates some fifteen times; filing false bar complaints against him; procuring and filing perjurious sworn statements about him in many litigations; infiltrating his office; tapping his phones; stealing his documents; threatening him and his family; disseminating hundreds or thousands of black PR publications about him; framing him with the forgery of a $2,000,000 check; attempting to have him prosecuted on false criminal charges; and according to Flynn, even trying to assassinate him. CSI, Scientology, Miscavige and the beneficiaries are further barred from bringing this action because before they compromised Flynn, as described in the preceding paragraph, and before they coerced and tricked Armstrong into signing their mutual release in December 1986, CSI, Scientology, Miscavige and the beneficiaries subjected Armstrong to five years of their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR and using the law to harass and ruin utterly, specifically, including, but not limited to, hiring individuals who followed and spied on Armstrong and his wife, created disturbances and upset his neighbors and fellow workers, assaulted him, struck him bodily with a car, attempted to involve him in a freeway accident, and threatened to assassinate him by putting a bullet between his eyes; attempting to entrap him in the commission of a crime; illegally videotaping him; filing false criminal charges against him with the Los Angeles District Attorney; filing false criminal charges against him with the Boston office of the FBI; filing false declarations to bring contempt of court proceedings against him on multiple occasions; obtaining perjured affidavits from English private investigators who had harassed him in London, England in 1984, accusing him of distributing "sealed" documents; disseminating internationally Scientology black PR publications, including to media, government agencies and officials and law enforcement departments and officials, falsely accusing Armstrong of, inter alia, crimes, including crimes against humanity; culling and disseminating information from his supposedly confidential auditing or psychotherapy file; and breaking into his car and stealing an original manuscript, artwork and other valuable documents. CSI, Scientology, Miscavige and the beneficiaries are further barred from bringing this action because, beginning immediately after they coerced and tricked Armstrong into signing their mutual release in December 1986, and for more than fifteen years right up to present time, they have continued to subject him to their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, specifically, including, but not limited to, threatening Armstrong with prosecution if he responded to third parties' legal subpoenas; hiring other individuals who followed, spied on and videotaped Armstrong, created disturbances and upset his neighbors and friends; publishing thousand of black PR attacks on Armstrong and disseminating them internationally including to media, government agencies and officials and law enforcement departments and officials, falsely claiming that, among other lies, Armstrong was connected to kidnappers, that he is incompetent, that he wanted to organize a coup against CSI, Scientology, Miscavige and the beneficiaries, that he has adopted a degraded life-style, that he stole millions of dollars of materials, that he is a pathological liar, that he posed nude for a newspaper, and on and on and on; threatening and terrifying Armstrong's friends and associates; procuring and filing false sworn statements about Armstrong in many litigations; suing Armstrong five times on bogus or illegal bases; forcing Armstrong into bankruptcy because of CSI's, Scientology's, Miscavige's and the beneficiaries' own illegal actions; having their personnel assault Armstrong during peaceful pickets; running multiple covert intelligence operations against Armstrong which continue to this day; attempting to have Armstrong prosecuted criminally on false charges and because of CSI's, Scientology's, Miscavige's and the beneficiaries' own illegal actions; corrupting this Court to get it to act illegally in abetting CSI's, Scientology's, Miscavige's and the beneficiaries' fair gaming of Armstrong by illicitly giving its power and authority to CSI, Scientology, Miscavige and the beneficiaries to harass and utterly ruin him, including by this Court's issuance of its illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane injunction, its contempt orders, and its arrest warrants against Armstrong; driving Armstrong from his job by CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and threatening activities, illegally abetted by this Court; driving Armstrong from California by CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and threatening activities, illegally abetted by this Court; driving Armstrong from Nevada by CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and threatening activities, illegally abetted by this Court; and driving Armstrong and his fiancée from British Columbia to Europe by CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and threatening activities, illegally abetted by this Court. CSI, Scientology, Miscavige and the beneficiaries are further barred from bringing this action because they subjected Minton and the LMT to their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, specifically, including, but not limited to, threatening Minton with prosecution, pursuant to the illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane terms of CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release, and this Court's equally illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable injunction, if Minton acted "in concert" with Armstrong in any way; assaulting Minton on multiple occasions; trespassing on his property; spying on him and his friends, disturbing and upsetting them; threatening his family; filing false criminal charges against him; and mounting a massive global Black PR campaign against Minton and the LMT, including to media, government agencies and officials and law enforcement departments and officials, falsely claiming that, among other lies, Minton is a criminal, Minton is responsible for thousands of deaths, Minton stole billions of dollars, Minton is insane, Minton wants to destroy a religion, the LMT was a hate group, the LMT wanted to destroy a religion, the LMT's staff were criminals, and on and on.

FIFTH AFFIRMATIVE DEFENSE (Fraud and Deceit)

40. Further answering said complaint, and as a fifth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 39 and 41 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, because of CSI's, Scientology's, Miscavige's and the beneficiaries' fraud and deceit in representing to Armstrong for the purpose of obtaining his signature on their mutual release, that by their mutual release CSI, Scientology, Miscavige and the beneficiaries sought to end litigation with Armstrong and the other Flynn clients and others with whom they were settling; that by their mutual release CSI, Scientology, Miscavige and the beneficiaries sought peace; that by the settlement CSI, Scientology, Miscavige and the beneficiaries wanted the opportunity to reform and discontinue their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly; that their mutual release with Armstrong was mutual; that the false affidavit that CSI, Scientology, Miscavige and the beneficiaries required Armstrong to sign as a condition of the settlement would be disclosed or used only if Armstrong attacked them; that CSI, Scientology, Miscavige and the beneficiaries would leave Armstrong alone and never again subject him to their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, to which they had been subjecting him prior to the December 1986 settlement; and, that CSI, Scientology, Miscavige and the beneficiaries, and none of them, were going to ever again engage in any way in any of their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, in which they had been engaging, and attacking Armstrong, his friends, associates, attorneys and other wog victims and targets prior to the December 1986 settlement. CSI, Scientology, Miscavige and the beneficiaries made the foregoing representations to Armstrong and to others with knowledge of the falsity thereof at the time said representations were made and with the intent to deceive Armstrong, and others, who actually and justifiably relied on those material misrepresentations to his, and others', injury by signing the mutual release. In fact, CSI, Scientology, Miscavige and the beneficiaries did not intend to end litigation with Armstrong; did not seek peace; did not want the opportunity to reform and discontinue their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly; did not consider that their mutual release with Armstrong was mutual; did not intend to not disclose and not use the false affidavit that CSI, Scientology, Miscavige and the beneficiaries required Armstrong to sign as a condition of the settlement unless Armstrong attacked them first; did not intend to leave Armstrong alone and never again subject him to CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, to which they had been subjecting Armstrong prior to the December 1986 settlement; and, did not intend to never again engage in any way in any of CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, in which they had been engaging, and attacking Armstrong, his friends, associates, attorneys and other wog victims and targets prior to the December 1986 settlement. Rather, CSI, Scientology, Miscavige and the beneficiaries intended to use the mutual release as a tool for the implementation of their illegal and noxious policies and practices, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly; to engineer a reversal of the judgment in Armstrong I; to collusively resolve any retrial of Armstrong I; to obtain possession of the so-called MCCS tapes which were evidence of CSI, Scientology, Miscavige and the beneficiaries employing attorneys for the purpose of committing future crimes and frauds; to use the false declaration in other litigation without regard to Armstrong's conduct; to suppress evidence of facts that discredited CSI, Scientology, Miscavige and the beneficiaries; to obstruct justice and deny redress, due process, and equal protection of the law to their civil and criminal victims; to continue to wage war on Armstrong and CSI's, Scientology's, Miscavige's and the beneficiaries' other wog targets; and, ultimately, through the claimed lawful judicial enforcement of the mutual release, to illegally fair game Armstrong into silence, and all those who might in any way support him, using the power and authority and the appearance of legality, probity and justice of the US and California courts, including this Court, to punish Armstrong, and all those who might in any way support him, for his speaking the truth about CSI, Scientology, Miscavige and the beneficiaries and about fair game, black PR, use of the law to harass and ruin utterly, and their other illegal and noxious policies and practices, and, through the illegal fair gaming and illegal judicial silencing and punishing of Armstrong, and all those who might in any way support him, to rewrite CSI's, Scientology's, Miscavige's and the beneficiaries' antisocial and criminal history, which Armstrong knows and speak about. CSI, Scientology, Miscavige and the beneficiaries are further barred from bringing this action because Flynn acted as their agent in defrauding and deceiving Armstrong at the time of the December 1986 settlement in order to get Armstrong's signature on the mutual release so that CSI, Scientology, Miscavige and any of the beneficiaries could thereafter subject Armstrong to their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, and, through CSI's, Scientology's, Miscavige's and the beneficiaries' claimed lawful judicial enforcement of the mutual release, illegally fair game Armstrong into silence, and all those who might in any way support him, using the power and authority and the appearance of legality, probity and justice of the US and California courts, including this Court, punish Armstrong, and all those who might in any way support him, for his speaking the truth about CSI, Scientology, Miscavige and the beneficiaries and about fair game, black PR, use of the law to harass and ruin utterly, and their other illegal and noxious policies, practices and acts, and, through the illegal fair gaming and illegal judicial silencing and punishing of Armstrong, and all those who might in any way support him, rewrite CSI's, Scientology's, Miscavige's and the beneficiaries' antisocial and criminal history, which Armstrong knew and spoke about and knows and speaks about. Flynn, as an agent of CSI, Scientology, Miscavige and the beneficiaries, and while representing himself to Armstrong to be Armstrong's attorney, stated to Armstrong, for the purpose of deceiving Armstrong into signing the mutual release, that the terms of the mutual release, which CSI, Scientology, Miscavige and the beneficiaries are claiming are lawful and judicially enforceable, which by their complaint they are seeking to judicially enforce, which this Court has previously enforced, and which this Court has previously punished Armstrong for breaching by assessment of hundreds of thousands of dollars in liquidated damages, by fines and by imprisonment, were "not worth the paper they're printed on," and "unenforceable." Flynn, as an agent of CSI, Scientology, Miscavige and the beneficiaries, and while representing himself to Armstrong to be Armstrong's attorney, also stated to and advised Armstrong, for the purpose of deceiving Armstrong into signing the mutual release, which on its face stripped Armstrong of his Constitutional rights, that "you can't sign away your Constitutional rights." Flynn made this statement to Armstrong knowing it was untrue, for the purpose of getting Armstrong to sign the mutual release so that CSI, Scientology, Miscavige or any of the beneficiaries could thereafter subject Armstrong to their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, and, through CSI's, Scientology's, Miscavige's and the beneficiaries' claimed lawful judicial enforcement of the mutual release, illegally fair game Armstrong into silence, and all those who might in any way support him, using the power and authority and the appearance of legality, probity and justice of the US and California courts, including this Court, punish Armstrong, and all those who might in any way support him, for his speaking the truth about CSI, Scientology, Miscavige and the beneficiaries and about fair game, black PR, use of the law to harass and ruin utterly, and their other illegal and noxious policies, practices and acts, and, through the illegal fair gaming and illegal judicial silencing and punishing of Armstrong, and all those who might in any way support him, rewrite CSI's, Scientology's, Miscavige's and the beneficiaries' antisocial and criminal history, which Armstrong knew and spoke about and knows and speaks about. As a further deception, to obtain Armstrong's signature on CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release, Flynn stated to Armstrong that, in the event that, after Armstrong signed the mutual release, CSI, Scientology, Miscavige or the beneficiaries subjected Armstrong to their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, or to any lawsuit or action to judicially enforce the terms of the mutual release which Flynn represented to Armstrong were "not worth the paper they're printed on," and "unenforceable," which CSI, Scientology, Miscavige and the beneficiaries are now seeking to judicially enforce here with their complaint, and which this Court has already illegally enforced, he, Flynn, "will be there for you." Flynn made the statement that he would be there for Armstrong knowing the statement was untrue since Flynn had already entered into an illegal agreement or contract with CSI, Scientology, Miscavige and the beneficiaries to never thereafter represent or assist Armstrong in any way, or any other person in any way, against CSI, Scientology, Miscavige or the beneficiaries, even if CSI, Scientology, Miscavige or any of the beneficiaries attempted to judicially enforce the mutual release. Flynn made the statement that he would be there for Armstrong knowing the statement was untrue for the purpose of deceiving Armstrong into signing the mutual release so that CSI, Scientology, Miscavige or any of the beneficiaries could thereafter subject Armstrong to their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, and, through CSI's, Scientology's, Miscavige's and the beneficiaries' claimed lawful judicial enforcement of the mutual release, illegally fair game Armstrong into silence, and all those who might in any way support him, using the power and authority and the appearance of legality, probity and justice of the US and California courts, including this Court, punish Armstrong, and all those who might in any way support him, for his speaking the truth about CSI, Scientology, Miscavige and the beneficiaries and about fair game, black PR, use of the law to harass and ruin utterly, and their other illegal and noxious policies, practices and acts, and, through the illegal fair gaming and illegal judicial silencing and punishing of Armstrong, and all those who might in any way support him, rewrite CSI's, Scientology's, Miscavige's and the beneficiaries' antisocial and criminal history, which Armstrong knew and spoke about and knows and speaks about. Armstrong relied on the truth of the statements and representations of Flynn that the terms of the mutual release, which CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce against Armstrong, Minton, the LMT, Does 1 through 50, and anyone else in the world who "acts in concert" in any way with Armstrong, are not worth the paper they're printed on and unenforceable; that Armstrong couldn't, by signing CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release, sign away his Constitutional rights; and, that, in the event that, after Armstrong signed the mutual release, CSI, Scientology, Miscavige and the beneficiaries subjected Armstrong to their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, or to any lawsuit or action to judicially enforce the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries are now seeking to judicially enforce here with their complaint, Flynn would be there for Armstrong, in Armstrong's signing of the mutual release. CSI, Scientology, Miscavige and the beneficiaries are further barred from bringing this action because they are continuing to perpetrate the fraud and deceit that the terms of the mutual release which CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce against Armstrong, Minton, the LMT, Does 1 through 50, and anyone else in the world who "acts in concert" in any way with Armstrong, are lawful and legally judicially enforceable, and that Armstrong agreed to those terms when he signed CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release. The terms of their mutual release that CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce against Armstrong, Minton, the LMT, Does 1 through 50, and anyone else in the world who "acts in concert" in any way with Armstrong, are in fact and in truth illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, and Armstrong never agreed to those terms when he signed the mutual release, since said terms are in fact and in truth illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable. Indeed, CSI, Scientology, Miscavige and the beneficiaries have for years perpetrated upon this Court their fraud and deceit that the terms of the mutual release, which CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce against Armstrong, Minton, the LMT, Does 1 through 50, and anyone else in the world who "acts in concert" in any way with Armstrong, are lawful and legally judicially enforceable, and that Armstrong agreed to those terms when he signed the mutual release. This Court relied upon the truth of CSI's, Scientology's, Miscavige's and the beneficiaries' fraudulent and deceitful representations that the terms of the mutual release, which CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce against Armstrong, Minton, the LMT, Does 1 through 50, and anyone else in the world who "acts in concert" in any way with Armstrong, are lawful and legally judicially enforceable, and that Armstrong agreed to those terms when he signed the mutual release, when this Court on multiple occasions and now for more than seven years, illegally abetted CSI's, Scientology's, Miscavige's and the beneficiaries' fair gaming of Armstrong by illicitly giving its power and authority to CSI, Scientology, Miscavige and the beneficiaries to harass and utterly ruin Armstrong, including by this Court's assessment of hundreds of thousands of dollars in liquidated damages against him, by this Court's illegal and unjust denial of a fair trial, or any trial, to Armstrong, by this Court's issuance of its injunction against him which is itself illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane, by this Court's illegal enforcement of its injunction against him by fines and imprisonment, and by this Court's illegal issuance of warrants for his arrest. This Court is itself promulgating CSI's, Scientology's, Miscavige's and the beneficiaries' fraud and deceit when it has declared and declares that that the terms of the mutual release which CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce against Armstrong, Minton, the LMT, Does 1 through 50, and anyone else in the world who "acts in concert" in any way with Armstrong, are lawful and legally judicially enforceable, and that Armstrong agreed to those terms when he signed the mutual release. This Court's promulgating of CSI's, Scientology's, Miscavige's and the beneficiaries' fraud and deceit is knowing and willful because this Court's record in this case contains rulings and statements by other California Superior Court Judges denouncing the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce, and refusing to enforce them; because Armstrong and his attorney Ford Greene have stated and demonstrated to this Court, supported by ample evidence and law, that the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable; and because simple human logic and the smallest sense of decency would lead to the inevitable conclusion that said terms are illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical and insane.

SIXTH AFFIRMATIVE DEFENSE (Duress and Undue Influence)

41. Further answering said complaint, and as a sixth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 40 and 42 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, because, for years prior to the December 1986 settlement, CSI, Scientology, Miscavige and the beneficiaries had subjected Flynn, Armstrong and Flynn's many other clients who were also victims or targets of CSI, Scientology, Miscavige and the beneficiaries, to CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, and if Armstrong did not sign the mutual release he, Flynn and Flynn's several other clients who were also victims or targets of CSI, Scientology, Miscavige and the beneficiaries, would be the victims or targets of CSI's, Scientology's, Miscavige's and the beneficiaries' continuing, additional, renewed and new attacks pursuant to their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly. Further, in early December 1986, Flynn, acting as an agent for CSI, Scientology, Miscavige and the beneficiaries, positioned Armstrong as a deal breaker, by, among other things, stating that the desires of Flynn and his attorney associates or co-counsels to settle in litigations against CSI, Scientology, Miscavige and the beneficiaries would be ruined unless Armstrong agreed to sign CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release, and led Armstrong to believe that if Armstrong did not sign the agreement, his attorneys would not cooperate in such event by acting as zealous advocates on the trial of his cross-complaint against Scientology set to commence shortly thereafter in Armstrong I. Flynn stated moreover to Armstrong prior to Armstrong's signing the mutual release, and for the purpose of coercing Armstrong to sign the mutual release, that CSI, Scientology, Miscavige and the beneficiaries, through their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, had destroyed Flynn's marriage, destroyed his life, threatened his law practice, threatened his children, and that he, Flynn, just had to get out so as to no longer be a target of CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly. Flynn, by his statements, led Armstrong to believe that if Armstrong did not sign CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release, Armstrong would be the cause of CSI, Scientology, Miscavige and the beneficiaries carrying out continuing, additional, renewed and new attacks on Flynn, his family, his attorney associates and his law practice pursuant to CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies and practices, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly.

SEVENTH AFFIRMATIVE DEFENSE (Estoppel)

42. Further answering said complaint, and as a seventh, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 41 and 43 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are equitably estopped from asserting each and all of the purported causes of action in their complaint by reason of CSI's, Scientology's, Miscavige's and the beneficiaries' own acts, omissions, and conduct, including, but not limited to, the facts that CSI, Scientology, Miscavige and the beneficiaries subjected and continue to subject Armstrong, Minton and the LMT, and other wogs, to CSI's, Scientology's, Miscavige's and the beneficiaries' irreligious, dangerous, destructive, abusive and criminal policies, practices and acts, including fair game, Black PR and using the law to harass and ruin utterly; that CSI, Scientology, Miscavige and the beneficiaries violated the terms of the mutual release which CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce, by, among other things, providing information from Armstrong I to various persons and in various litigations, before Armstrong ever responded publicly, including, but not limited to, The London Sunday Times, The Los Angeles Times, the litigation of Bent Corydon v. Scientology, the litigation of Scientology v. Russell Miller and Penguin Books Limited in London, England, wherein CSI, Scientology, Miscavige and the beneficiaries filed multiple affidavits attacking and black PRing Armstrong, and Church of Spiritual Technology v. US, wherein CSI, Scientology, Miscavige and the beneficiaries black PRed Armstrong and filed the false affidavit that CSI, Scientology, Miscavige and the beneficiaries required Armstrong to sign as a condition of the settlement; and that CSI, Scientology, Miscavige and the beneficiaries discussed, published, attacked and black PRed, and continue to discuss, publish, attack and black PR Armstrong's experiences with and knowledge about CSI, Scientology, Miscavige and the beneficiaries, the very experiences with and knowledge about CSI, Scientology, Miscavige and the beneficiaries which CSI, Scientology, Miscavige and the beneficiaries seek by their complaint here to prevent Armstrong from mentioning, and to punish him for mentioning in any way whatsoever. As yet a further basis for barring plaintiff on the ground of estoppel, Armstrong requested on multiple occasions during the litigation of Armstrong II, III, IV and V that CSI, Scientology, Miscavige release Flynn and Armstrong's other former attorneys from the agreements or contracts they signed never to represent or assist Armstrong again against CSI, Scientology, Miscavige and the beneficiaries, and CSI, Scientology, Miscavige and the beneficiaries have refused to do so.

EIGHTH AFFIRMATIVE DEFENSE (Waiver)

43. Further answering said complaint, and as a eighth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 42 and 44 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, by reason of CSI's, Scientology's, Miscavige's and the beneficiaries' own acts, omissions and conduct. By subjecting Armstrong, after their settlement with him, to their irreligious, dangerous, destructive, abusive and criminal policies, practices and acts, such as fair game, black PR and using the law to harass and ruin utterly, and by discussing, publishing, attacking and black PRing Armstrong's experiences with and knowledge about CSI, Scientology, Miscavige and the beneficiaries, CSI, Scientology, Miscavige and the beneficiaries have acted to waive any right whatsoever they have or ever had to enforce the terms of the mutual release CSI, Scientology, Miscavige and the beneficiaries are by their complaint here seeking to judicially enforce, against Armstrong, Minton, or the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert with Armstrong, or not acting in concert with Armstrong.

NINTH AFFIRMATIVE DEFENSE (Mistake Of Law)

44. Further answering said complaint, and as a ninth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 43 and 45 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, because Armstrong's former attorney Michael Flynn advised Armstrong that the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce were not in any way enforceable, that said terms are not worth the paper they're printed on, and that Armstrong could not sign away his Constitutional rights. Armstrong relied on such representations, but for which he would not have signed said mutual release.

TENTH AFFIRMATIVE DEFENSE (Mistake Of Fact)

45. Further answering said complaint, and as a tenth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 44 and 46 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, because Flynn advised Armstrong that the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce were not in any way enforceable, that said terms are not worth the paper they're printed on, and that Armstrong could not sign away his Constitutional rights. Armstrong relied on such representations, but for which he would not have signed said mutual release.

ELEVENTH AFFIRMATIVE DEFENSE (Conflict of Interest)

46. Further answering said complaint, and as an eleventh, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 45 and 47 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, because Flynn, in conjunction with settling Armstrong's case against Scientology-related entities, also settled numerous other cases, including cases of his own against Scientology-related defendants without procuring outside counsel for Armstrong. Flynn acted as an agent of CSI, Scientology, Miscavige and the beneficiaries in contravention of Flynn's ethical and legal obligations to Armstrong in tricking, defrauding, deceiving, pressuring and coercing Armstrong into signing CSI's, Scientology's, Miscavige's and the beneficiaries' mutual release so that CSI, Scientology, Miscavige or any of the beneficiaries could thereafter subject Armstrong to their illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, and, through CSI's, Scientology's, Miscavige's and the beneficiaries' claimed lawful judicial enforcement of the mutual release, illegally fair game Armstrong into silence, and all those who might in any way support him, using the power and authority and the appearance of legality, probity and justice of the US and California courts, including this Court, punish Armstrong, and all those who might in any way support him, for Armstrong's speaking the truth about CSI, Scientology, Miscavige and the beneficiaries and about fair game, black PR, use of the law to harass and ruin utterly, and their other illegal and noxious policies, practices and acts, and, through the illegal fair gaming and illegal judicial silencing and punishing of Armstrong, and all those who might in any way support him, rewrite CSI's, Scientology's, Miscavige's and the beneficiaries' antisocial and criminal history, which Armstrong knew and spoke about and knows and speaks about.

TWELFTH AFFIRMATIVE DEFENSE (Laches)

47. Further answering said complaint, and as an twelfth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 46 and 48 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds of laches.

THIRTEENTH AFFIRMATIVE DEFENSE (Impossibility)

48. Further answering said complaint, and as an thirteenth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 47 and 49 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds of impossibility. What CSI, Scientology, Miscavige and the beneficiaries seek here to compel Armstrong to do and punish him for not doing by judicial enforcement of their mutual release, and what this Court has already punished Armstrong for not doing with assessments of hundreds of thousands of dollars in liquidated damages, with contempt orders, with imprisonment orders, and with warrants for his arrest, specifically, not communicating one word about CSI, Scientology, Miscavige or the beneficiaries, or about their attributes, policies, practices or actions that are irreligious, dangerous, destructive, abusive or criminal, or religious, safe, constructive, compassionate or lawful, or about CSI's, Scientology's, Miscavige's and the beneficiaries' victimizing, fair gaming, black PRing or targeting of persons such as Armstrong, or about CSI's, Scientology's, Miscavige's and the beneficiaries' efforts to rewrite their antisocial and criminal history, or about anything else of any nature whatsoever relating in any way to CSI, Scientology, Miscavige or the beneficiaries, and not assisting or advising anyone, including individuals, partnerships, associations, corporations, or governmental agencies involved in or contemplating any activity adverse to the interests of CSI, Scientology, Miscavige or the beneficiaries, is a physical impossibility because it is contrary to the course of nature; it is a practical impossibility because it can only be done at an unreasonable and excessive cost, to wit, Armstrong's death; it is a subjective impossibility because, as Armstrong has demonstrated for over twenty years in hundreds of thousands of communications, and despite unceasing fair game attacks, despite multiple lawsuits including this one, despite a mountain of black PR, and despite a never ending threat to his life, his psychological makeup will not permit it; it is an objective impossibility because CSI, Scientology, Miscavige and the beneficiaries by making Armstrong their target and victim have forced him to do what they insist he not do, as demonstrated even by this answer to CSI's, Scientology's, Miscavige's and the beneficiaries' complaint; and it is a Divine Impossibility because the people that CSI, Scientology, Miscavige and the beneficiaries seek with their complaint to prevent Armstrong from advising or assisting, and which this Court would punish him for advising or assisting, are each and every one the more than six billion wogs in the world, every child of God in the universe.

FOURTEENTH AFFIRMATIVE DEFENSE (Frustration of Contractual Purpose)

49. Further answering said complaint, and as an fourteenth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 48 and 50 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds of frustrating defendants', and each of their, ability to perform the terms of the settlement agreement.

FIFTEENTH AFFIRMATIVE DEFENSE (Unfair and Unreasonable Contract)

50. Further answering said complaint, and as an fifteenth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 49 and 51 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds that the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries are by their complaint here seeking to enforce, in addition to being illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable, are unfair and unreasonable as to defendant Armstrong, and consequently unfair and unreasonable as to Minton, the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert with Armstrong, or not acting in concert with Armstrong.

SIXTEENTH AFFIRMATIVE DEFENSE (Lack of Mutuality)

51. Further answering said complaint, and as an sixteenth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 50 and 52 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds that the mutual release, as interpreted by CSI, Scientology, Miscavige and the beneficiaries, and as they are attempting to enforce it here by their complaint, lacks in reciprocity and mutuality.

SEVENTEENTH AFFIRMATIVE DEFENSE (Ambiguity)

52. Further answering said complaint, and as an seventeenth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 51 and 53 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds that the mutual release at issue herein is ambiguous and incapable of enforcement.

EIGHTEENTH AFFIRMATIVE DEFENSE (Lack of Adequate Consideration)

53. Further answering said complaint, and as an eighteenth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 52 and 54 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds that the mutual release, and specifically the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to judicially enforce against Armstrong, Minton, the LMT, Does 1 through 50, and anyone else in the world who "acts in concert" in any way with Armstrong, are not supported by adequate consideration. Armstrong has in the past publicly stated that he would only contract away the rights CSI, Scientology, Miscavige and the beneficiaries claim they contracted away from Armstrong, except for the right to communicate in any way, manner or medium about CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, including fair game, black PR, and use of the law to harass and ruin utterly, for fifteen trillion dollars (U.S.$15,000,000,000,000). Armstrong's figure in present time, and for this universe and this universe alone, is four quadrillion dollars (U.S.$4,000,000,000,000,000). Armstrong has never contracted away and will never contract away his right to communicate in any way, manner or medium about CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, use of the law to harass and ruin utterly, because such a contract is illegal, being a contract of blackmail. Armstrong has steadfastly refused to participate in CSI's, Scientology's, Miscavige's and the beneficiaries' illegal blackmail scheme, even when this Court abetted said illegal blackmail scheme by prohibiting Armstrong from communicating about CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, use of the law to harass and ruin utterly, by punishing Armstrong from communicating about CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, use of the law to harass and ruin utterly, and by this Court's issuance of its illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane and clearly unenforceable injunction, this Court's issuance of its illegal contempt orders, and this Court's issuance of its consequently illegal warrants for Armstrong's arrest.

NINETEENTH AFFIRMATIVE DEFENSE (Unconscionability)

54. Further answering said complaint, and as a nineteenth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 53 and 55 through 79 paragraphs herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds that the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries are by their complaint here seeking to enforce, in addition to being illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane, clearly unenforceable, unfair and unreasonable, are unconscionable.

TWENTIETH AFFIRMATIVE DEFENSE (Adhesion)

55. Further answering said complaint, and as a twentieth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 54 and 56 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds that the mutual release is a contract of adhesion.

TWENTY-FIRST AFFIRMATIVE DEFENSE (Hardship)

56. Further answering said complaint, and as a twenty-first, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 55 and 57 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds that the terms of the mutual release which CSI, Scientology, Miscavige and the beneficiaries are seeking to enforce here by their complaint would work, and do work, an unfair hardship on Armstrong, and on Minton, the LMT, Does 1 through 50, and any person, Scientologist or wog, who might in any way act in concert with Armstrong.

TWENTY-SECOND AFFIRMATIVE DEFENSE (Offset)

57. Further answering said complaint, and as a twenty-second, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 56 and 58 through 79 herein and alleges as follows: Any damages that CSI, Scientology, Miscavige and the beneficiaries, or any of them, have suffered in consequence of the alleged conduct of Armstrong, Minton and the LMT, Does 1 through 50, or anyone, Scientologist or wog, acting in concert in any way with Armstrong, is exceeded by the damages suffered by Armstrong, Minton and the LMT, Does 1 through 50, and anyone, Scientologist or wog, acting in concert in any way with Armstrong, in consequence of CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts directed at Armstrong, Minton and the LMT, Does 1 through 50, and anyone, Scientologist or wog, acting in concert in any way with Armstrong, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, and therefore CSI, Scientology, Miscavige and the beneficiaries should take nothing.

TWENTY-THIRD AFFIRMATIVE DEFENSE (Liquidated Damages Act As Penalty)

58. Further answering said complaint, and as a twenty-third, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 57 and 58 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds that the mutual release's provision of liquidated damages was never negotiated, and is in no way whatsoever an approximation of any damages CSI, Scientology, Miscavige and the beneficiaries would or might suffer as a result of Armstrong, Minton, the LMT, Does 1 through 50, or anyone else, Scientologist or wog, acting in concert with Armstrong, breaching the terms or any of the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries are seeking to enforce here by their complaint; but the liquidated damages provision in the mutual release is intended to act and does act impermissibly as punishment or a penalty.

TWENTY-FOURTH AFFIRMATIVE DEFENSE (Implied Covenant of Good Faith and Fair Dealing)

59. Further answering said complaint, and as a twenty-fourth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 58 and 60 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, on the grounds that the conduct of CSI, Scientology, Miscavige and the beneficiaries violates the implied covenant of good faith and fair dealing.

TWENTY-FIFTH AFFIRMATIVE DEFENSE (Failure to Mitigate Damages)

60. Further answering said complaint, and as a twenty-fifth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 59 and 61 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton and the LMT, and each of them, because CSI, Scientology, Miscavige and the beneficiaries failed to take proper and reasonable steps to avoid or mitigate the damages alleged in the complaint, and to the extent of such failure to avoid or mitigate, damages allegedly incurred by CSI, Scientology, Miscavige or any of the beneficiaries, if any, should be reduced accordingly. In willful, flagrant violation of their duty to avoid or mitigate their damages, CSI, Scientology, Miscavige and the beneficiaries have acted to maximize their damages by subjecting Armstrong for more than twenty years, and continuously and relentlessly to CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, which required that to defend himself Armstrong breach the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek to enforce here by their complaint; and CSI, Scientology, Miscavige and the beneficiaries created, by subjecting Armstrong to CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, an environment in which it was impossible for Armstrong to not breach the terms of the mutual release which CSI, Scientology, Miscavige and the beneficiaries seek to enforce here by their complaint. CSI, Scientology, Miscavige and the beneficiaries are further barred from bringing this action against Armstrong, Minton and the LMT, and each of them, because in willful, flagrant violation of their duty to avoid or mitigate their damages, CSI, Scientology, Miscavige and the beneficiaries have acted to maximize their damages by subjecting Minton and the LMT, and others, including, but not limited to, Does 1 through 50, and anyone, wog or Scientologist, acting in concert in any way with Armstrong, to CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, which required that Minton and the LMT, and others, including, but not limited to, Does 1 through 50, and anyone, wog or Scientologist, to defend themselves, and others, had to, and must, act in concert with Armstrong in breaching the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek to enforce here by their complaint; and CSI, Scientology, Miscavige and the beneficiaries created, by subjecting Minton and the LMT, and others, including, but not limited to, Does 1 through 50, and anyone, wog or Scientologist, acting in concert in any way with Armstrong, to CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly, an environment in which it was impossible for Minton and the LMT, and others, including, but not limited to, Does 1 through 50, and anyone, wog or Scientologist, acting in concert in any way with Armstrong, to not breach the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek to enforce here by their complaint.

TWENTY-SIXTH AFFIRMATIVE DEFENSE (Terms Cannot Be Specifically Enforced)

61. Further answering said complaint, and as a twenty-sixth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 60 and 62 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from judicial relief because the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek to enforce here by their complaint cannot be specifically enforced.

TWENTY-SEVENTH AFFIRMATIVE DEFENSE (Terms Cannot Be Specifically Performed)

62. Further answering said complaint, and as a twenty-seventh, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 61 and 63 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from judicial relief because the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek to enforce here by their complaint cannot be specifically performed.

TWENTY-EIGHTH AFFIRMATIVE DEFENSE (Res Judicata)

63. Further answering said complaint, and as a twenty-eighth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 62 and 64 through 79 herein and alleges as follows: CSI's, Scientology's, Miscavige's and the beneficiaries' complaint, and their claims for equitable relief and for damages, against Armstrong, Minton, the LMT, Does 1 through 50, and any other person, Scientologist or wog, acting in any way in concert with Armstrong, are barred by the doctrine of res judicata.

TWENTY-NINTH AFFIRMATIVE DEFENSE (Collateral Estoppel)

64. Further answering said complaint, and as a twenty-ninth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 63 and 65 through 79 herein and alleges as follows: CSI's, Scientology's, Miscavige's and the beneficiaries' complaint, and their claims for equitable relief and for damages, against Armstrong, Minton, the LMT, Does 1 through 50, and any other person, Scientologist or wog, acting in any way in concert with Armstrong, are barred by the doctrine of collateral estoppel. . THIRTIETH AFFIRMATIVE DEFENSE (Action Barred By Equity and Civil Code Provisions)

65. Further answering said complaint, and as a thirtieth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 64 and 66 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from judicial relief by the general principles of equity and the specific provisions of Part IV of the California Civil Code, including but not limited to §§ 3512, 3513, 3514, 3517, 3519, 3520, 3521, 3523, 3524, 3528, 3531, 3533, 3542, 3543, 3545, 3546, 3547 and 3548.

THIRTY-FIRST AFFIRMATIVE DEFENSE (Void As Against Public Policy)

66. Further answering said complaint, and as a thirty-first, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 65 and 67 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from judicial relief because the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek to enforce here by their complaint are void as against public policy.

THIRTY-SECOND AFFIRMATIVE DEFENSE (Right to Counsel)

67. Further answering said complaint, and as a thirty-second, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 66 and 68 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from judicial relief because the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek to enforce here by their complaint deprive Armstrong of his right to counsel as protected by the California Constitution and by the Sixth Amendment to the U.S. Constitution.

THIRTY-THIRD AFFIRMATIVE DEFENSE (Public Domain)

68. Further answering said complaint, and as a thirty-third, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 67 and 69 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from judicial relief because the information that CSI, Scientology, Miscavige and the beneficiaries accuse Armstrong of disclosing is in the public domain.

THIRTY-FOURTH AFFIRMATIVE DEFENSE (Privilege)

69. Further answering said complaint, and as a thirty-fourth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 68 and 70 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from judicial relief because the acts CSI, Scientology, Miscavige and the beneficiaries accuse Armstrong, Minton, the LMT, Does 1 through 50, or anyone else, wog or Scientologist, acting in concert in any way with Armstrong, of having committed, were and are privileged.

THIRTY-FIFTH AFFIRMATIVE DEFENSE (Justification - Defense of Another, Interests of Third Persons, and the Public)

70. Further answering said complaint, and as a thirty-fifth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 69 and 71 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from judicial relief because, at all relevant times, the acts CSI, Scientology, Miscavige and the beneficiaries accuse Armstrong, Minton, the LMT, Does 1 through 50, or anyone else, wog or Scientologist, acting in concert in any way with Armstrong, of having committed, were and are privileged and justified because they were done in the defense of others, the interests of third parties, the interests of justice, and the interests of the public.

THIRTY-SIXTH AFFIRMATIVE DEFENSE (Privacy)

71. Further answering said complaint, and as a thirty-sixth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 70 and 72 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton, the LMT, Does 1 through 50, or anyone else, wog or Scientologist, acting in concert in any way with Armstrong, or not acting in concert in any way with Armstrong, on the grounds that the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek here to enforce by their complaint violate the right of privacy of Armstrong, Minton, the LMT, Does 1 through 50, and anyone else, wog or Scientologist, acting in concert in any way with Armstrong, or not acting in concert in any way with Armstrong, guaranteed by the U.S. and California Constitutions.

THIRTY-SEVENTH AFFIRMATIVE DEFENSE (Due Process)

72. Further answering said complaint, and as a thirty-seventh, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 71 and 73 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from judicial relief because the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek to enforce here by their complaint deprive Armstrong, Minton, the LMT, Does 1 through 50, wogs or Scientologists acting in concert in any way with Armstrong, other third parties, and the public of due process of law as protected by the California Constitution and by the Fifth and Fourteenth Amendments to the U.S. Constitution.

THIRTY-EIGHTH AFFIRMATIVE DEFENSE (Equal Protection)

73. Further answering said complaint, and as a thirty-eighth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 72 and 74 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from judicial relief because the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek to enforce here by their complaint deprive Armstrong, Minton, the LMT, Does 1 through 50, wogs or Scientologists acting in concert in any way with Armstrong, other third parties, and the public of equal protection of law as guaranteed by the California Constitution and by the U.S. Constitution.

THIRTY-NINTH AFFIRMATIVE DEFENSE (First Amendment - Speech)

74. Further answering said complaint, and as a thirty-ninth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 73 and 75 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton, the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert in any way with Armstrong on the grounds that the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek here to enforce by their complaint violate the right of Armstrong, Minton, the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert in any way with Armstrong, and each of them, to freedom of speech guaranteed by the California and U.S. Constitutions.

FORTIETH AFFIRMATIVE DEFENSE (First Amendment - Press)

75. Further answering said complaint, and as a fortieth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 74 and 76 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton, the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert in any way with Armstrong on the grounds that the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek here to enforce by their complaint violate the right of Armstrong, Minton, the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert in any way with Armstrong, and each of them, to freedom of press guaranteed by the California and U.S. Constitutions. Armstrong is a well-known, respected correspondent for the Usenet Newsgroup Alt.Religion. Scientology. The URL for Armstrong's Internet Publication, which contains many of his writings and documents, including writings and documents concerning CSI, Scientology, Miscavige and the beneficiaries, their illegal or noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly, their illegal fair gaming and illegal judicial silencing and punishing of Armstrong, and their efforts to rewrite their antisocial and criminal history, which he knows and speak about, is http://www.gerryarmstrong.org.

FORTY-FIRST AFFIRMATIVE DEFENSE (First Amendment - Religion)

76. Further answering said complaint, and as a forty-first, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 75 and 77 through 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton, the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert in any way with Armstrong on the grounds that the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries seek here to enforce by their complaint violate the right of Armstrong, Minton, the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert in any way with Armstrong, and each of them, to freedom of religion guaranteed by the California and U.S. Constitutions. Further, CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton, the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert in any way with Armstrong because Armstrong is the founder and leader of the Church of Wogs®, hereinafter "CoW" ®. CoW's Mission Statement has been published as follows:

The Church of Wogs ®. The Church of Wogs ® shall defend, support and promote Wogs ® and what is worthy in the Wog World ®. Any Wog ® may join. The Church of Wogs (CoW) ® shall be truly pan-denominational. Any Wog ® of any belief, creed or faith may join. Any Wog ® of any race, gender, nationality, age or status may join. For decades, good Wogs ® have been persecuted for their beliefs and activities. CoW ® shall shelter these beliefs and activities, and work assiduously to oppose those who would persecute any of us. Any Wog ® may work to defend, support and promote Wogs ® and what is worthy in the Wog World ®, and oppose Wogs' ® persecutors. CoW ® also opposes the persecution of those who have abandoned the Wog World ®. Nevertheless, both the persecutors and the persecuted who have abandoned the Wog World ® wage an unjust War on Wogs (WoW!)®, and on Wog ® arts, sciences, institutions and enterprises. CoW ® is determined to bring peace in this war being waged on Wogs ®. The Creed of the Church of Wogs ®: We of the Church hold: 1. That Wogs ® are equal. The Church of Wogs (CoW)® will persist beyond how long the War on Wogs (WoW!) ® persists. CoW ® seeks every being on earth. CoW's mission is to wake sleeping Wogs ®, and to defend, support and promote all Wogs ® until the war is won. © 2001 Gerry Armstrong

The URL for the Church of Wogs is http://www.gerryarmstrong.org/50grand/cow/index.html. "Wog" is an epithet, which CSI, Scientology, Miscavige and the beneficiaries use to designate a class of hominids determined by Hubbard, and now by CSI, Scientology, Miscavige and the beneficiaries according to their own religious, pseudo-religious or pseudo-scientific criteria. CSI, Scientology, Miscavige and the beneficiaries have for decades persecuted wogs, and waged an oppressive, evil and deadly war on wogs, started by Hubbard, employing, among other weapons and tactics, CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies and practices, including, but not limited to, fair game, black PR, and using the law to harass and ruin utterly. Hubbard directed, and now CSI, Scientology, Miscavige and the beneficiaries direct that Scientologists and their organizations are to treat every skirmish with wogs as war. Hubbard published an intention, which CSI, Scientology, Miscavige and the beneficiaries still publish to this day, to dispose of undesirable wogs, who do not measure up to CSI's, Scientology's, Miscavige's and the beneficiaries' religious, pseudo-religious, pseudo-scientific, pseudo-legal or criminal standards, quietly and without sorrow. Hubbard taught and directed, and CSI, Scientology, Miscavige and the beneficiaries still teach and direct, that wogs are inferior, less aware, less able, less ethical and less intelligent than Scientologists, and are to be controlled by Scientologists. Hubbard taught and directed, and CSI, Scientology, Miscavige and the beneficiaries still teach and direct, that wog mental health professionals are evil and criminals, and are to be vilified, attacked and ruined, and that the whole wog mental health field is evil and criminal, and is to be destroyed and replaced by CSI, Scientology, Miscavige and the beneficiaries. Hubbard taught and directed, and CSI, Scientology, Miscavige and the beneficiaries still teach and direct, that wog justice systems do not work, are criminal, are to be taken over, and are to be used for the illegal purpose of harassing and utterly ruining CSI's, Scientology's, Miscavige's and the beneficiaries' wog targets in CSI's, Scientology's, Miscavige's and the beneficiaries' war on wogs. This Court, which is a part of the wog justice system, has, for at least seven years, been collaborating with CSI, Scientology, Miscavige and the beneficiaries in the persecution of wogs, and in CSI's, Scientology's, Miscavige's and the beneficiaries' waging of their oppressive, evil and deadly war on wogs, by giving this Court's power and authority and this Court's appearance of legality, probity and justice to CSI, Scientology, Miscavige and the beneficiaries to punish Armstrong for speaking the truth about CSI, Scientology, Miscavige and the beneficiaries, the truth about their war on wogs, and the truth about CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, use of the law to harass and ruin utterly, and by facilitating, through this Court's abetting of the illegal fair gaming and illegal judicial silencing and punishing of Armstrong, CSI's, Scientology's, Miscavige's and the beneficiaries' rewriting of their antisocial and criminal history, which Armstrong knows and speak about. Armstrong is a wog who has been given a role by God to oppose CSI's, Scientology's, Miscavige's and the beneficiaries' persecution of wogs, to fight back in CSI's, Scientology's, Miscavige's and the beneficiaries' oppressive, evil and deadly war on wogs, to expose CSI's, Scientology's, Miscavige's and the beneficiaries' war on wogs since CSI, Scientology, Miscavige and the beneficiaries wage their war on wogs principally by covert means and by secret intelligence operations, and to defend wogs who are persecuted, attacked, fair gamed, black PRed, or harassed or ruined by CSI's, Scientology's, Miscavige's and the beneficiaries' use of wog law. Wogs are God's children, and God has always raised up and will always raise up wogs, as He has raised up Armstrong, to defend His children who are persecuted and warred upon, even though the persecutors and wagers of war also are His children. Further, CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton, the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert in any way with Armstrong because CSI, Scientology, Miscavige and the beneficiaries are radically anti-Christian, and Armstrong is a Christian, possessing an inalienable right from God Himself, also granted by the U.S. and California Constitutions, which this Court cannot legally strip from him, to defend his faith and religion, and oppose, by speech and writing in any medium, the anti-Christians comprising CSI, Scientology, Miscavige and the beneficiaries, who attack and seek to destroy Armstrong's religion. Hubbard taught and directed, and CSI, Scientology, Miscavige and the beneficiaries still teach and direct, that there is no Christ, that God is an electronic implant installed in wogs by an intergalactic tyrant Xenu seventy-five million years ago to enslave wogs, and that only CSI, Scientology, Miscavige and the beneficiaries have the technology, for which they charge in the neighborhood of $360,000, to free wogs from the enslavement of Christ, God and religion. Armstrong knows that Hubbard's, and CSI's, Scientology's, Miscavige's and the beneficiaries' "technology" is fraudulent, that in fact it is itself designed to enslave people, and that Hubbard's and CSI's, Scientology's, Miscavige's and the beneficiaries' assertions, teachings and directions that there is no Christ and that God is an electronic implant designed by Xenu to enslave wogs, are themselves implants in CSI's, Scientology's, Miscavige's and the beneficiaries' oppressive, evil and deadly war on wogs, and are utterly false, irreligious, suppressive, dangerous and cruel. CSI's, Scientology's, Miscavige's and the beneficiaries' public statements that Scientology is compatible with Christianity and that CSI, Scientology, Miscavige and the beneficiaries support freedom of religion, and other civil rights, are utter lies, designed to deceive and defraud all wogs, including Christian wogs, and to soften up wogs, including Christian wogs, and render them vulnerable, easy targets for CSI's, Scientology's, Miscavige's and the beneficiaries' war on wogs, and for CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly. Armstrong possesses an inalienable right from God Himself, also granted by the U.S. and California Constitutions, which this Court cannot legally strip from him, to expose the lies of CSI, Scientology, Miscavige and the beneficiaries about Armstrong's religion, his fellow Christians, his fellow wogs, Christ, God, enslavement, implants, CSI's, Scientology's, Miscavige's and the beneficiaries' war on wogs, softening up wogs, Scientology's incompatibility with Christianity, CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly, and about anything else related to CSI, Scientology, Miscavige and the beneficiaries, to oppose and seek to reform CSI, Scientology, Miscavige and the beneficiaries in their war on wogs, attacks on Christianity, Christ and God, and to oppose and seek to reform CSI's, Scientology's, Miscavige's and the beneficiaries' efforts to soften up wogs, both Christian and non-Christian, and to implant wogs, who are God's children, both Christian and non-Christian, and deceive them into joining CSI's, Scientology's, Miscavige's and the beneficiaries' war on wogs, into participating in CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly, and into slaving to deceive and recruit ever more wogs into joining CSI's, Scientology's, Miscavige's and the beneficiaries' war on wogs, participating in CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly, and slaving to war on, deceive and recruit ever more wogs. Further, CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton, the LMT, Does 1 through 50, or anyone, wog or Scientologist, acting in concert in any way with Armstrong because Armstrong is a Prophet to Scientologists, hereinafter "PtS"®, and as a PtS possesses an inalienable right from God Himself, also granted by the U.S. and California Constitutions, which this Court cannot legally strip from him, to bring the Word of God, by speech and writing in any medium, to Scientologists, whom CSI, Scientology, Miscavige and the beneficiaries implant, suppress, oppress, enslave and turn to hate with their lies about Christ, God, wogs, religion, science, Hubbard, Xenu, "body thetans, " hereinafter "BTs," and many other subjects, with CSI's, Scientology's, Miscavige's and the beneficiaries' oppressive, evil and deadly war on wogs, and with CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly. CSI, Scientology, Miscavige and the beneficiaries teach and direct all Scientologists that they are saving the planet, and Armstrong as a PtS brings the message to them that God is saving the planet. CSI, Scientology, Miscavige and the beneficiaries teach and direct all Scientologists that they must put their faith in Scientology and in their lies about Christ, God, wogs, religion, science, Hubbard, Xenu, BTs, etc., in CSI's, Scientology's, Miscavige's and the beneficiaries' oppressive, evil and deadly war on wogs, and in CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly, and Armstrong as a PtS brings the message to Scientologists that they should put their faith in God.

FORTY-SECOND AFFIRMATIVE DEFENSE (This Court Cannot Enjoin The Practice Of A Profession)

77. Further answering said complaint, and as a forty-second, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 76 and 78 through 79 herein and alleges as follows: Any attempt by CSI, Scientology, Miscavige and the beneficiaries to limit the ability to obtain gainful employment by Armstrong, Minton, the LMT, Does 1 through 50, anyone else acting in concert in any way with Armstrong, or any of them, is void and unenforceable as a matter of public policy, and constitutes an unenforceable restraint on the right of defendants, or any of them, to pursue their chosen profession inasmuch as CSI's, Scientology's, Miscavige's and the beneficiaries' complaint is based upon communications and acts by Armstrong in his professional capacity as Prophet to Scientologists.

FORTY-THIRD AFFIRMATIVE DEFENSE (First Amendment - Association)

78. Further answering said complaint, and as a forty-third, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 77 and 79 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton, the LMT, Does 1 through 50, and anyone, Scientologist or wog, acting in concert in any way with Armstrong, or any of them, on the grounds that the terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to enforce violate the right of Armstrong, Minton, the LMT, Does 1 through 50, and anyone, Scientologist or wog, acting in concert in any way with Armstrong, to freedom of association guaranteed by the U.S. and California Constitutions. As a victim and target of CSI's, Scientology's, Miscavige's and the beneficiaries' oppressive, evil and deadly war on wogs, and of CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly, as a wog, as a Christian, as the leader of the CoW, and as a PtS, Armstrong necessarily must associate with the very people that CSI, Scientology, Miscavige and the beneficiaries seek to prevent him from associating with by the illegal, unconstitutional, greatly stupid, impossible to perform, anti-public policy, anti-American, anti-religion, diabolical, insane, clearly unenforceable, unfair, unreasonable and unconscionable terms of the mutual release that CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to enforce, to wit, wogs such as Minton, the LMT, Does 1 through 50, and anyone acting in concert in any way with Armstrong, who are themselves victim or targets of CSI's, Scientology's, Miscavige's and the beneficiaries' oppressive, evil and deadly war on wogs, and of CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly, or Scientologists who participate in CSI's, Scientology's, Miscavige's and the beneficiaries' oppressive, evil and deadly war on wogs, and of CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly.

FORTY-FOURTH AFFIRMATIVE DEFENSE (Thirteenth Amendment - Freedom from Slavery)

79. Further answering said complaint, and as a forty-fourth, separate and affirmative defense thereto, Armstrong repeats, realleges and incorporates by reference herein each and every allegation contained in the introduction and paragraphs 1 through 78 herein and alleges as follows: CSI, Scientology, Miscavige and the beneficiaries are barred from bringing this action against Armstrong, Minton, the LMT, Does 1 through 50, and anyone, Scientologist or wog, acting in concert in any way with Armstrong, or any of them, on the grounds that the terms of the mutual release which CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to enforce make slaves of Armstrong, Minton, the LMT, Does 1 through 50, and anyone, Scientologist or wog, acting in concert in any way with Armstrong, and force them into involuntary servitude to CSI, Scientology, Miscavige and the beneficiaries, which is prohibited every place in the United States by the Thirteenth Amendment to the U.S. Constitution. The terms of the mutual release which CSI, Scientology, Miscavige and the beneficiaries by their complaint here are seeking to enforce, and this Court's interpretation of said terms, permit CSI, Scientology, Miscavige and the beneficiaries to wage their oppressive, evil and deadly war on Armstrong, Minton, the LMT, Does 1 through 50, and anyone, Scientologist or wog, acting in concert in any way with Armstrong, and subject them to CSI's, Scientology's, Miscavige's and the beneficiaries' illegal and noxious policies, practices and acts, including fair game, black PR, and use of the law to harass and ruin utterly, and do not permit Armstrong, Minton, the LMT, Does 1 through 50, and anyone, Scientologist or wog, acting in concert in any way with Armstrong, to respond to defend themselves or each other in any way, and punish Armstrong, Minton, the LMT, Does 1 through 50, and anyone, Scientologist or wog, acting in concert in any way with Armstrong, if any of them do respond to defend themselves or each other in any way, with fines and imprisonment.

DEMAND FOR JURY TRIAL

Defendant Armstrong hereby demands that this case be tried by a jury.

WHEREFORE, Armstrong prays for relief as follows:

1. That neither CSI, Scientology, Miscavige, nor any of the beneficiaries take anything by their complaint;

2. That Armstrong recover his costs of suit herein;

3. That, should Armstrong retain an attorney to defend him, he recover his attorney's fees and costs of defending the suit herein;

4. That the Court award such further relief as it may deem proper.

Respectfully submitted,
[Signed] Armstrong

DATED: November 5, 2002
GERRY ARMSTRONG

PROOF OF SERVICE

I am a citizen of Canada and reside in Germany. I am over the age of eighteen years and am not a party to the within action. My business address is c/o Dialog Zentrum Berlin Heimat 27, D-14165 Berlin-Zehlendorf, Germany.

I served the following document

Answer of Gerry Armstrong

on the following persons on the date set forth below, by delivering a true copy thereof enclosed in a sealed envelope to the addressees below:

Andrew H. Wilson, Esquire
WILSON CAMPILONGO LLP
475 Gate 5 Road
Sausalito, CA 94965
U.S.A.

Benjamin K. Riley, Esquire
COOLEY GODWARD LLP
One Maritime Plaza, 20th Floor
San Francisco, CA 94111-3580
U.S.A.

by causing such envelope with postage thereon fully prepaid to be placed in the German Mail in Berlin, Germany.

I declare under penalty of perjury under the laws of Germany and the United States that the above is true and correct.

Executed on November 7, 2002 at Berlin, Germany

[Signed] C Letkeman Caroline Letkeman

http://www.gerryarmstrong.org/50grand/legal/a7/armstrong-answer-cv021632.html

© Gerry Armstrong http://www.gerryarmstrong.org