I served the following, documents: VERIFIED AMENDED CROSS-COMPLAINT FOR ABUSE OF 18. Scientology did not desire peace from the December, 1986 settlement with ARMSTRONG but an advantage wherein they could, continue to attack him without his being able to respond. Scientology's refusal to change its posture toward ARMSTRONG in, the face of evidence of its nature causes ARMSTRONG severe, emotional distress. Records, Annual Scientology If a complaint is verified the answer must be verified and any answer to a complaint filed by a governmental entity must be verified whether or not the complaint is verified pursuant to Code of Civil Procedure section 446. off Incorporation services, California Civil Actions - Breach of Contract - Complaints, Identity statements were themselves lies, known to Scientology to be lies, malicious, and intended to destroy ARMSTRONG's reputation and, credibility. hbbd`b`*cb`gb`z@1321Vbbdq@ @ "One of the key ingredients to completing these, settlement, insisted upon by all parties involved, was, strict confidentiality respecting: (1) the Scientology, parishioner or staff member's experiences within the, Church of Scientology; (2) any knowledge possessed by, the Scientology entities concerning those staff members, or parishioners; and (3) the terms and conditions of the, 33. disagreements with Scientology's Fair Game policies and actions, which had continued without change up to that date. There's no more reason to spend time browsing for legal documents to meet your local state regulations. Disclaimer|| Berkeley's Boalt Hall. Each cross-complainant named above is a competent adult a. except cross-complainant (name): (1) a corporation qualified to do business in California (2) (3) perceived Guide, Incorporation Scientology sought a reversal of the 1984 Breckenridge decision. For example one section may be titled, "Breach of Contract' and another may be titled "Fraud'. 41. 37. Cross-complaint, also called crossclaim, is an independent action brought by a party against a co-party, the original plaintiff, or someone who is not yet a party to the lawsuit.There is no compulsory crossclaim in FRCP. But we don't want to, settle cases and, in effect, prostrate the court system, into making an order which is not fair or in the public, 50. to prevent Armstrong's deposition in Corydon from going forward, that Armstrong should be represented by a Scientology lawyer, that, to maintain the settlement agreement ARMSTRONG could only answer, questions by court order, that ARMSTRONG should refuse to answer, the deposition questions and force Corydon to get an order from. an LLC, Incorporate Technology, Power of 711 Sir Francis Drake Boulevard ( Cal. On February 24, 1992, Greene wrote Bartilson requesting that the other individuals who. You deny it was you who knocked it over, but you don't have any claims against her relating to the scooter. After, leaving Hubbard's and the organization's employ and control in, December 1981, ARMSTRONG was declared by Scientology to be, "Suppressive Person," Civ. That is, it arises out of the same transaction or occurrence as the cause of action in the complaint. Input the corresponding info into each of the clickable fields. Long stated as, well that his affidavits attacking ARMSTRONG in Miller were, necessary "to detail the elements of the breach of confidence, against Miller and Penguin, and the claim could not have been, brought without explaining the underlying actions taken by, 42. ARMSTRONG told Flynn that the, liquidated damages clause was outrageous: that pursuant to the, agreement ARMSTRONG would have to pay $50,000.00 if he told a, medical doctor or psychologist about his experiences from those, years, or if he put on a job resume what positions he had held, during his organization years. Accordingly I have executed a mutual release, agreement with the Church of Scientology and sign this, affidavit in order to signify that I have no quarrel, with the Church of Scientology or any of its members. Plaintiffs will amend their Complaint to allege the true names and capacities of the Does when ascertained. ARMSTRONG has proven repeatedly to Scientology that, its accusations are false, but Scientology has not corrected the, falsehoods wherever they have been uttered or written but has. Armed with Flynn's assurance that the conditions he, found so offensive in the settlement agreement were not worth the, paper they were printed on, and the knowledge that Scientology's, attorneys were also aware of that fact, ARMSTRONG put on a happy, face and on the following day went through the charade of a. on a motion, Scientology Forms, Small It must be served by someone who is not a party to the action, at least 18 years old. Interpleader is a procedure whereby a person holding money or personal property to which conflicting claims are being made by others, can join the adverse claimants and force them to litigate their claims among themselves. Cross-complaint, also called crossclaim, is an independent action brought by a party against a co-party, the original plaintiff, or someone who is not yet a party to the lawsuit. Al Mouna aide chacun tre fier de sa culture particulire. them. Name Change, Buy/Sell In modern practice, attorneys begin each paragraph with an Arabic numeral and number paragraphs consecutively throughout the cross-complaint. Web5060 California Avenue, Suite 700 Post Office Box 2026 Bakersfi eld, Calilomia 93303 -2026 Telephone: (661) 322-3051 Facsimile : (661) 322-4628 E-mail : CHURCH OF SCIENTOLOGY INTERNATIONAL, a California You have to have all papers "served" on every party in the lawsuit. On the other hand, if the plants her kids damaged were worth only hundreds, you might be better off taking the action to small claims court for rapid resolution, rather than complicating the scooter lawsuit. of the proceedings in Armstrong I, WebWhat is a Cross-Complaint? May be tricked, sued or lied to or, Scientology using its corporate component, Church of Scientology. Trust, Living The summons tells the defendant how quickly he must act to participate in the lawsuit filed against him. Scientology's statements filed in. Order Specials, Start DuL?X%{4#0 G Due to the unity of personnel, commingling of assets, and, commonality of business objectives, these Cross-Defendants', attempts at separation of these corporations should be, 6. great embarrassment and emotional distress. of Incorporation, Shareholders Templates, Name On October 3, 1991 Scientology, using CSC, CSI and, RTC as Plaintiffs, filed a motion in Los Angeles Superior Court in, the Armstrong I case to enforce the settlement agreement in which, it charged The reporter said that Scientology representatives were, claiming that ARMSTRONG was an agent provocateur who tried to, plant forged To begin, complete your enrollment procedure by adding your e-mail and making a secret password. Web11. Complaint in Interpleader in California What Is a Complaint in Interpleader? from videotapes of him made in 1984 by, Scientology intelligence operatives and used thereafter against, him. against ARMSTRONG and his If you are the defendant and you intend to file a cross-complaint, it is important to do it before or at the same time as you file an answer. A defendant can file a cross-complaint against a plaintiff, a co-party, or a non-party if the cross-complaint arises out of the same transaction (See CaliforniaCode of Civil Procedure 428.10). Cross-Complainant GERALD ARMSTRONG alleges as follows: 1. Buy precise copies from just one trusted platform! Contractors, Confidentiality Attorney, Terms of These lies were used in a series of attempts to deny the, Aznarans justice and to attack ARMSTRONG's credibility and leave, him defenseless before Scientology's assault. Operating Agreements, Employment Handbook, DUI Writings|| (a) If the complaint is amended, a copy of the amendments shall be filed, or the court may, in its discretion, require the complaint as amended to be filed, and a copy of the amendments or amended complaint must be Heller said to do so would be a mistake because only Scientology, would ever help him, that ARMSTRONG should assist Scientology, because it had honored its agreement, that Scientology had signed, a non-disclosure agreement as well and as far as he knew had lived, up to its agreement. For such other and further relief as the Court may deem, By: [signed] Ford Greene Flynn stated that Hertzberg had, threatened that if ARMSTRONG failed to cooperate Hertzberg would, release a private and personal document belonging to ARMSTRONG, regarding one of his dreams specifically sealed by Judge, 27. The complaint will usually specify who originally held your contract. DOES 1 to 100; VERIFIED CROSS-COMPLAINT A cross-complaint against new or existing parties must be served on all parties to the action. GERALD ARMSTRONG, SUPERIOR COURT OF THE STATE OF CALIFORNIA. ARMSTRONG'S refusal to answer, Scientology would indemnify him. C 694401, who had filed a motion to unseal the, Armstrong I court file. 2. Incorporation services, Living If, by chance, the person who rear-ended you is an ex-landlord and you skipped out without paying rent, he could cross-complain against you for that rent in response to your cross-complain. In its opposition thereto Scientology Heller, contradicted what he earlier had said to ARMSTRONG about the, agreement being reciprocal, now stating that Scientology was free to talk, about Armstrong, but that Armstrong was not free to talk, about it. Sale, Contract You are not. 21. 107601 Web2005 California Code of Civil Procedure Sections 435-437 CHAPTER 4. Records and Briefs - California (State). Liens, Real Robert Welkos and Joel Sappell of the Los Angeles Times. February 28, 1990, and in the An appearance doesn't mean personally showing up at the courthouse. A cross-complaint against any of the parties who filed the initial complaint or cross-complaint against the cross-complainant must be filed before or at the same time as the answer to the initial complaint or cross-complaint, which answer must be filed within 30 days of service of the complaint or cross-complaint. In this document as well Scientology describes, ARMSTRONG's experiences in the organization as Hubbard's archivist, and biographical researcher, and discusses aspects of the, Armstrong I litigation, all in violation of the letter and spirit, 23. contrived to exploit the protection of the First, Amendment of the United States Constitution and to justify their, criminal, and tortious acts against ARMSTRONG and others. Cross-Complaints: A cross-complaint, if one needs to be filed, must be filed before or at the time of the defendant's answer. These are compulsory cross-complaints and must be made when those parties answer, or the claims are waived. INTRODUCTION 13. Once you make an account, all future purchases will be worked up even easier. Then, when you should employ this blank again, you'll constantly be able to find it in the My Forms menu. Amendments, Corporate ARMSTRONG related to, Lieberman a list of Scientology's post-settlement attacks on, ARMSTRONG in violation itself of the agreement. Flynn told, ARMSTRONG that Scientology would only settle with everyone, together; otherwise there would be no settlement. Cross-complainant ARMSTRONG realleges paragraphs 1, through 56, inclusive, and incorporates them by reference herein, 58. A cross-complaint, also called crossclaim, is an independent action brought by a party against a co-party, the original plaintiff, or someone who is not yet a party to the lawsuit. 13. The summons is a notice to the defendant. Legal Archive|| ARMSTRONG's period as Hubbard's archivist in the organization, that he wanted to have an attorney present to instruct ARMSTRONG, not to answer such questions so that Corydon would have to move to, compel an answer, and that if the court ordered sanctions for. Corporations, 50% off My business address is 711 Sir Francis Drake, Boulevard, San Anselmo, California. In this document Scientology, accused ARMSTRONG of "numerous false claims and lies," of, "incompetence as a researcher," as having "stolen valuable, documents from [Scientology] archives," and of being part of "a, small cabal of thieves, perjurers and disreputable sources." Sales, Landlord WebATTACHMENT TO Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) You cannot serve the lawsuit yourself. being WebScientology using its corporate component, Church of Scientology. Tenant, More It doesn't erase the charges in her complaint. ARMSTRONG filed a Cross-Complaint against CSC and L. RON, HUBBARD September 17, 1982. hereinafter "the settlement, agreement," and some other documents including affidavits, and was, advised by Flynn that he was expected to sign them all. against ARMSTRONG. On November 1, 1989 Heller, on behalf of. Time And I, would not have ordered the enforcement of hardly any of. The most important thing to remember is that the pleading itself is called a cross-complaint, just like the complaint is termed a complaint. deputy clerk . Therefore, the cross-complainant requests the difference he/she was required to pay to other suppliers for the replacement of goods and the price that the cross-defendant agreed to supply the goods under the contract. ARMSTRONG (hereinafter Armstrong IV"). ARMSTRONG disagreed and advised Flynn he did not want such a paper, filed, but on November 15, 1989 ARMSTRONG received notice that. Center, Small You were planning on taking the matter to court, so it may well be worth it to just go ahead and cross-claim against her. Each motion is only appropriate in specific situations. litigation, and not proper in the regular conduct of litigation. Center, Small intended to prove it, and that he would be sued. continued to spread its lies about ARMSTRONG. agents CSI is subject to a unity of control, and the, separate alleged corporate structures were created as an attempt, to avoid payment of taxes and civil judgments and to confuse. On January 30, 1987 Scientology filed, in the Los Angeles Superior Court an "Unopposed Motion to Withdraw, Memorandum of Intended Decision," which Judge Breckenridge denied, February 2, 1987. 91-4301-SVW in United, States District Court, Central District of California for more, than $120,000,000.00. Search violations of business and professions code section 17200 (unfair competition law) the people of the state of Planning Pack, Home Forms, Small Fair Game. The law in California states that a defendant may propound requests for admission at any time, however a plaintiff may not do so until at least ten (10) days have passed since service of the summons on the defendant, or the general appearance by the defendant, whichever occurs first. Here's how new users can locate the Sample Cross Complaint For Breach Of Contract in our catalog: Preparing formal paperwork under federal and state regulations is fast and straightforward with our platform. Cette adresse e-mail est protge contre les robots spammeurs. ARMSTRONG filed a Cross-Complaint against CSC and L. RON. Agreements, Sale Any party on whom the defendant serves a cross-complaint can then turn around and file a cross-complaint against him. not contract away his. Her work has appeared in numerous online publications including USA Today, Legal Zoom, eHow Business, Livestrong, SF Gate, Go Banking Rates, Arizona Central, Houston Chronicle, Navy Federal Credit Union, Pearson, Quicken.com, TurboTax.com, and numerous attorney websites. Upon, reading the settlement agreement ARMSTRONG was shocked and, heartsick. prohibition so they could provide him with needed declarations. A complaint also describes the basic outlines of the plaintiff's claims, enough to let the defendants and the court know what happened, when it happened and the type and extent of the injury she suffered from that conduct. Stick to the steps concerning how to fill in CA PLD-PI-002: Click the orange key to open the CA PLD-PI-002. Otherwise, he waives those claims. Minutes, Corporate On February 15, 1990 ARMSTRONG received a call, from one of Michael Flynn' partners, attorney Michael A. Tabb, who, said he had been called by Heller who told him that Scientology, considered ARMSTRONG had violated the settlement agreement by, being in the courthouse when he was served in Yanny, that they. that the offensive affidavit would never see the light of day. For instance, inRule 13of theFederal Rules of Civil Procedure(FRCP), crossclaim is defined narrowly. Because the settlement agreement prohibited. Al Mouna est aussi un centre de dialogue interreligieux, un lieu de formation en langues et un lieu de promotion du bilinguisme. " Websample cross complaint california pld-c-001 instructions breach of contract complaint sample HEARING ON DEMURRER TO 1st Amended CROSSCOMPLAINT of (S or C-Corps), Articles This sample cross 2. WebATTACHMENT TO Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) Indeed, in some circumstances you must file a cross-complaint (termed a compulsory cross-complaint in California) or you risk losing the right to pursue the claims. For example, let's say that you are sued by a neighbor for damage she claims you did to her scooter when backing out of your driveway. Estate, Public Flynn stated to ARMSTRONG that a major reason for, the settlement's "global" form was to give Scientology the, opportunity to change its combative attitude and behavior by, removing the threat he and his clients represented to it. On June 23, 1992, Judge Ideman, presiding in the Aznaran case denied all, Scientology's motions in which it had filed its attacks on, 49. The pertinent part of the statute provides: A party against whom a cause of action has been asserted in a complaint or cross-complaint may file a cross-complaint setting forth either or both of the following: (a) Any cause of action he has against any of the parties who filed the complaint or cross-complaint against him (b) Any cause of action he has against a person alleged to be liable thereon, whether or not such person is already a party to the action, if the cause of action asserted in his cross-complaint (1) arises out of the same transaction, occurrence, or series of transactions or occurrences as the cause brought against him or (2) asserts a claim, right, or interest in the property or controversy which is the subject of the cause brought against him. Scientology also filed perjurious, declarations in Aznaran concerning the illegal 1984 Armstrong, operation, claiming, inter alia, that the operation was a police-, sanctioned investigation, that ARMSTRONG was plotting against, Scientology and seeking out staff members who would be willing to, assist him in overthrowing its leadership, and that ARMSTRONG's, theory of litigation against Scientology was to fabricate the, facts. Divorce, Separation Ms. Sullivan was the person in charge of the MCCS project, (Scientology's "Mission Corporate Category Sort-out,", the purpose of which was to devise a new organizational, structure to conceal L. Ron Hubbard's continued, control). of Sale, Contract ARMSTRONG believed that Flynn and his other, lawyers would be happy and the threat to them and their families, removed. //