Date: Fri, 20 Feb 2004 16:59:52 -0800
To: ahw@WilsonCampilongo.com
From: Gerry Armstrong <gerry@gerryarmstrong.org>
Subject: Nudge — third request for agreement to extension to file opposition to sj motion
February 20, 2004
Andrew H. Wilson, Esquire
Wilson Campilongo LLP
475 Gate 5 Road
Sausalito, CA 94965
U.S.A.
By E-Mail: ahw@WilsonCampilongo.com
Re: Scientology v. Armstrong, et al.
Marin Superior Court Case No. CV 021632
Dear Mr. Wilson:
I sent you the following letter yesterday referencing three earlier letters to which you had not properly responded:
1. My letter of February 11, 2004;
2. My letter of November 24, 2003;
3. My letter of November 26, 2003;
[Quote]
February 19, 2004
Andrew H. Wilson, Esquire
Wilson Campilongo LLP
475 Gate 5 Road
Sausalito, CA 94965
U.S.A.
By E-Mail: ahw@WilsonCampilongo.com
Re: Scientology v. Armstrong, et al.
Marin Superior Court Case No. CV 021632
Dear Mr. Wilson:
On February 11, 2004, I sent you, and Ms. Parker in your office, by e-mail the following letter requesting your agreement to a one month extension for filing my opposition to Scientology’s summary judgment motion:
[Quote]
Dear Mr. Wilson:
Because of a claimed “mistake” by the shipping company or companies handling the shipment of the belongings of Caroline Letkeman and myself, including what I need to complete my opposition to Scientology’s summary judgment, our shipment has been sent to another port in another country. Obviously, I suspect that this is no “mistake” and that the people who seek my obliteration pursuant to their policy are involved. I am, of course, investigating as feasible, and making whatever security arrangements are possible to protect our belongings. I have no guarantee when our shipment will be reshipped to us, but I will require at least another month extension for completing my opposition to the summary judgment motion.
I must send my request to the Marin Court right away, so please let me know immediately if you will agree to an extension of a month.
Yours sincerely,
Gerry Armstrong
[End Quote]
As of this date, February 19, 2004, I have received no response from you to my request.
As you are very aware, I have complained several times throughout the litigation of this case of your failure to respond to my communications and your failure to properly serve important documents on me.
See, e.g., this letter sent to you by e-mail on November 24, 2003:
[Quote]
November 24, 2003
Andrew H. Wilson, Esquire
Wilson Campilongo LLP
475 Gate 5 Road
Sausalito, CA 94965
U.S.A.
By E-Mail: ahw@WilsonCampilongo.com
Re: Scientology v. Armstrong, et al.
Marin Superior Court Case No. CV 021632
Dear Mr. Wilson:
I have received a pack of documents relating to Scientology’s summary judgment motion with a proof of service dated November 17, 2003 that states that a “Proposed Order” was served on me. There was no Proposed Order in the pack of materials I received. Please see:
http://www.gerryarmstrong.org/50grand/legal/a7/pos-mtn-sj-2003-11-17.html
This is not a small matter because of your habit of getting judges to sign patently unlawful orders.
Therefore, please serve your actual Proposed Order on me right away.
In your declaration in support of the summary judgment motion, you state at paragraph 10: “Attached hereto and incorporated herein as Exhibit I is a true and correct copy of the Opposition to Order to Show Cause re: Contempt and the Declaration of Gerald Armstrong in the matter entitled Church of Scientology International v. Gerald Armstrong, Marin Superior Court, Case No. 152229.”
This is false.
All that is attached as “Exhibit I” are the first two pages of said “Opposition to Order to Show Cause re: Contempt and the Declaration of Gerald Armstrong.” Please see:
http://www.gerryarmstrong.org/50grand/legal/a7/decl-wilson-2003-11-17.html
Please also serve on me right away therefore an actual “true and correct copy of the Opposition to Order to Show Cause re: Contempt and the Declaration of Gerald Armstrong in the matter entitled Church of Scientology International v. Gerald Armstrong, Marin Superior Court, Case No. 152229.”
And please file with the Court a correct declaration that includes an actual “true and correct copy of the Opposition to Order to Show Cause re: Contempt and the Declaration of Gerald Armstrong in the matter entitled Church of Scientology International v. Gerald Armstrong, Marin Superior Court, Case No. 152229.”
I see on the Marin Superior Court’s online calendar that the hearing on the summary judgment motion is set for February 10, 2003. http://www.co.marin.ca.us/depts/MC/main/courtcal/casenoq.cfm Your papers all state that the hearing date is February 3, 2003. If you have been given a different hearing date from the one you are giving on your papers, please advise me immediately.
Yours sincerely,
Gerry Armstrong
C/O DIALOG ZENTRUM BERLIN
Heimat 27
D-14165 Berlin-Zehlendorf
Germany
Tel: +49-30-815-7040
Fax: +49-1212-5-205-27-015
gerry@gerryarmstrong.org
[End Quote]
When I received no response from you, I sent you the following letter on November 26, 2003:
[Quote]
November 26, 2003
Andrew H. Wilson, Esquire
Wilson Campilongo LLP
475 Gate 5 Road
Sausalito, CA 94965
U.S.A.
By E-Mail: ahw@WilsonCampilongo.com
Re: Scientology v. Armstrong, et al.
Marin Superior Court Case No. CV 021632
Dear Mr. Wilson:
I have received no response to the following letter sent to you by e-mail on November 24. Please advise me right away as to your intention regarding serving me with the documents omitted from the Scientology cult’s summary judgment papers that I have so far received, and also about the date of the hearing on the cult’s motion, since the date you give is different from the Court’s.
Yours sincerely,
Gerry Armstrong
[Quote]
November 24, 2003
Andrew H. Wilson, Esquire
Wilson Campilongo LLP
475 Gate 5 Road
Sausalito, CA 94965
U.S.A.
By E-Mail: ahw@WilsonCampilongo.com
Re: Scientology v. Armstrong, et al.
Marin Superior Court Case No. CV 021632
Dear Mr. Wilson:
I have received a pack of documents relating to Scientology’s summary judgment motion with a proof of service dated November 17, 2003 that states that a “Proposed Order” was served on me. There was no Proposed Order in the pack of materials I received. Please see:
http://www.gerryarmstrong.org/50grand/legal/a7/pos-mtn-sj-2003-11-17.html
This is not a small matter because of your habit of getting judges to sign patently unlawful orders.
Therefore, please serve your actual Proposed Order on me right away.
In your declaration in support of the summary judgment motion, you state at paragraph 10: “Attached hereto and incorporated herein as Exhibit I is a true and correct copy of the Opposition to Order to Show Cause re: Contempt and the Declaration of Gerald Armstrong in the matter entitled Church of Scientology International v. Gerald Armstrong, Marin Superior Court, Case No. 152229.”
This is false.
All that is attached as “Exhibit I” are the first two pages of said “Opposition to Order to Show Cause re: Contempt and the Declaration of Gerald Armstrong.” Please see:
http://www.gerryarmstrong.org/50grand/legal/a7/decl-wilson-2003-11-17.html
Please also serve on me right away therefore an actual “true and correct copy of the Opposition to Order to Show Cause re: Contempt and the Declaration of Gerald Armstrong in the matter entitled Church of Scientology International v. Gerald Armstrong, Marin Superior Court, Case No. 152229.”
And please file with the Court a correct declaration that includes an actual “true and correct copy of the Opposition to Order to Show Cause re: Contempt and the Declaration of Gerald Armstrong in the matter entitled Church of Scientology International v. Gerald Armstrong, Marin Superior Court, Case No. 152229.”
I see on the Marin Superior Court’s online calendar that the hearing on the summary judgment motion is set for February 10, 2003. http://www.co.marin.ca.us/depts/MC/main/courtcal/casenoq.cfm Your papers all state that the hearing date is February 3, 2003. If you have been given a different hearing date from the one you are giving on your papers, please advise me immediately.
Yours sincerely,
Gerry Armstrong
C/O DIALOG ZENTRUM BERLIN
Heimat 27
D-14165 Berlin-Zehlendorf
Germany
Tel: +49-30-815-7040
Fax: +49-1212-5-205-27-015
gerry@gerryarmstrong.org
[End Quote]
[End Quote]
You still have not responded to these e-mails, and to my requests therein that you serve me with documents you claim were filed with Scientology’s summary judgment motion.
In your declaration executed February 5, 2004 in support of Scientology’s response to my earlier request for extension of time to file my opposition to the summary judgment motion, you stated:
[Quote]
2. On January 22, I received an email from Defendant Gerald Armstrong requesting additional time to file an opposition to Plaintiff’s Motion for Summary Judgment, a copy of which is attached hereto as Exhibit B.
3. As a result of receiving Mr. Armstrong’s email and reviewing the endorsed file copies of the motion papers, I discovered that the hearing had been set for February 10, rather than February 3. The motion papers had been prepared with a hearing date of February 3, based upon my understanding that this date had been reserved. My former secretary had apparently neglected to reserve this date, when he attempted to file the papers, had to manually change the date to February 10. Unfortunately, he neglected to inform me of this change.
[End Quote]
What a crock. I informed you of the February 10 hearing date back in November, 2003 in the above quoted two e-mails, neither of which you acknowledged. I still am waiting for you to serve me with the documents you state were filed with Scientology’s summary judgment motion that I requested in these e-mail letters:
1. “Proposed Order;”
2. “a true and correct copy of the Opposition to Order to Show Cause re: Contempt and the Declaration of Gerald Armstrong in the matter entitled Church of Scientology International v. Gerald Armstrong, Marin Superior Court, Case No. 152229,” your Exhibit I to your Declaration in Support of Motion for Summary Judgment executed November 17, 2003.
If you do not agree to a one-month extension for me to file my opposition to Scientology’s summary judgment motion, that’s up to you. But at least have the professionalism in this ten million dollar lawsuit to advise me that you do not agree.
And please respond to my communications and properly serve on me all documents that should be or should have been served.
Yours sincerely,
Gerry Armstrong
#1-45950 Alexander Avenue
Chilliwack, B.C. V2P 1L5
Canada
gerry@gerryarmstrong.org
[End Quote]
You still have not properly responded.
Please also be aware that my Complaint Report to the U.S. Department of Justice Civil Rights Division, a partial draft of which I served on you along with my request of the Court for a one month extension for filing my opposition to Scientology’s summary judgment motion, is webbed here:
http://www.gerryarmstrong.org/50grand/legal/a8/complaint-rpt-doj-2004-02-16.html
I of course request and expect that your client and you now cease all your actions toward me of any kind, judicial or extrajudicial, that constitute your conspiracy to deprive me of my rights and privileges secured to me by the U.S. Constitution and laws or to punish me for having exercised such rights and privileges.
Yours sincerely,
Gerry Armstrong
#1-45950 Alexander Avenue
Chilliwack, B.C. V2P 1L5
Canada
gerry@gerryarmstrong.org