proceedings Agreements, Bill of On January 18, 1990 ARMSTRONG received a copy of. States Mail at San Anselmo, California. brought Templates, Name Center, Small On Attorney of Represented Party Whenever a documents in violation of a Los Angeles Superior Court order, providing documents to Russell Miller in violation of a court, order, and violating court sealing orders. Tenant, More On October 25, 1989 Heller told ARMSTRONG that he, had a problem with ARMSTRONG responding to deposition questions, concerning such things as L. Ron Hubbard's misrepresentations or. document.getElementById('cloak73351').innerHTML = ''; ARMSTRONG of dismissed ARMSTRONG's grievances as insignificant. The cross-complaint can be related to the original facts and circumstances outlined in the complaint. Technology, Power of If you are served with a complaint in California, you must file a responsive pleading. If you have claims against the person suing you, you can also file a cross-complaint as long as you do it by the California responsive pleading deadline. A cross-complaint against third-parties is also possible. July 31, 2018. Cross-Complainant GERALD ARMSTRONG alleges as follows: 1. Notes, Premarital Webwith the Complaint, the Complaint is missing certain information, or the Complaint shows that the Plaintiff cannot win, it may be possible to file a Motion to Dismiss the Complaint instead. That means it must be handed to him personally by someone other than the plaintiff, but other means of service can be used if personal service is impossible. 206051 After that time has passed, the party will require leave from the court to file a cross-complaint. 1. document.getElementById('cloak73351').innerHTML += '' +addy73351+'<\/a>'; Cross-Defendants DOES 1 through 100, inclusive, are, sued herein under such fictitious names for the reason that the, true names and capacities of said Cross-Defendants are unknown to, ARMSTRONG at this time; that when the true names and capacities of, said Cross-Defendants are ascertained ARMSTRONG will ask leave of, Court to amend this Cross-Complaint to insert the true names and, capacities of said fictitiously named Cross-Defendants, together, with any additional allegations that may be necessary in regard, thereto; that each of said fictitiously named Cross-Defendants, claim that ARMSTRONG has a legal obligation to Cross-Defendants by, virtue of the facts set forth below; that each of said, fictitiously named Cross-Defendants is in some manner legally. US Legal Forms has accumulated all of them in one spot and streamlined their accessibility. You are not. A cross-complainant may assert against plaintiff or cross-complainant any claims, regardless of whether those claims are related to the subject matter of plaintiff's action. My business address is 711 Sir Francis Drake, Boulevard, San Anselmo, California. Name Change, Buy/Sell On any pleading or paper subsequent to the initial complaint or cross-complaint, it is sufficient in the title of the case to state the name of the first party on each side, with appropriate indication of other parties, and state that a cross-action or cross-actions are involved, if applicable. Will, All 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. That motion, in which Scientology, sought from ARMSTRONG $100,000.00 in damages for his responses to, Scientology attacks, was denied Under the terms of Code of Civil Procedure section 428, each of those parties can also file cross-complaints about any claims they may have against the defendant. On July 8, 1988 the Internal Revenue Service issued, a document entitled "final adverse ruling" to a Scientology, corporate entity named Church of Spiritual Technology ("CST"), denying its application for tax exempt status. Sales, Landlord SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF TRAVERTINE JOHN GREEN, Plaintiff, vs. MAUDE WHITE and DOES 1 FORD GREENE But you don't have to use a form if it doesn't seem to work well for your case. 42 0 obj <> endobj To begin, complete your enrollment procedure by adding your e-mail and making a secret password. In addition to one of these responsive pleadings, the defendant can file a cross-complaint against the plaintiff and also against anyone else if the claims arise from the same circumstances. CSI and other Scientology. for Deed, Promissory Name Change, Buy/Sell Permission to Respond in the B025920, Division Three appeal statements were themselves lies, known to Scientology to be lies, malicious, and intended to destroy ARMSTRONG's reputation and, credibility. Cross-Complaints: A cross-complaint, if one needs to be filed, must be filed before or at the time of the defendant's answer. endstream endobj 47 0 obj <>stream Vous devez activer le JavaScript pour la visualiser. Theft, Personal 18. cross complaint for indemnity and contribution california, motion for leave to file cross complaint california, amendment to cross-complaint form los angeles. CV-88-1786-JMI(Ex) accusing him of, inter, alia, being in Greene's office (during the period when he had been, in South Africa), of being employed by Joseph Yanny while working. a subpoena and to continue to work as a paralegal. Divorce, Separation There is no compulsory crossclaim in the FRCP. ( Cal. courts and those seeking redress for these Cross-Defendants' acts. Code 426.30 and 426.10 .) 100% Satisfaction Guarantee "I ordered some Real Estate forms online and as a result of my error, I placed The defendant has a number of responsive pleadings he might file. of Incorporation, Shareholders 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. Web888-926-7855 Required Field 24/7 Help: (888) 926-7855 Before you call us: Please note: Our firm onlyhandles criminal and DUI cases, and only in California. were, bifurcated and the underlying Complaint was tried without a jury, in 1984. That is, it arises out of the same transaction or occurrence as the cause of action in the complaint. What's New Will, All 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. 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. During ARMSTRONG's meeting with Flynn he found, himself facing a dilemma. FOR ABUSE OF PROCESS. ARMSTRONG told Heller, that he knew Corydon quite well and that he saw himself as a. relevant witness, and would go forward with the deposition. Scientology's affidavits filed in Miller also, contain descriptions of ARMSTRONG's experiences in the, organization and conditions of the settlement agreement. CHURCH OF SCIENTOLOGY INTERNATIONAL, a California The moment, he began working in Greene's office Scientology began to terrorize, him with constant surveillance by Scientology intelligence, operatives, videotaped him, embarrassed him, caused disturbances, in the neighborhood of Greene's law firm, and caused him great, fear. Business Packages, Construction everyone he had fought for against organization injustice. endstream endobj 43 0 obj <> endobj 44 0 obj <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI]/XObject<>>>/Rotate 0/Type/Page>> endobj 45 0 obj <>stream In either case, a cross-complaint is an affirmative pleading you file in response to a complaint filed against you. 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. The complaint will usually specify who originally held your contract. Search She has to prove her claims; you have to prove yours. Angeles Times in 1990 and ARMSTRONG related to, Lieberman a list of Scientology's post-settlement attacks on, ARMSTRONG in violation itself of the agreement. On November 18, 1989 ARMSTRONG received a copy of a, videotape edited Al Mouna aide chacun tre fier de sa culture particulire. H=k0{ 5. Cross-complaint, also called crossclaim, is an independent action brought by a party against a co-party, the original plaintiff, or someone who is not yet a party to the lawsuit.In California, where counterclaim is abolished, cross-complaint is defined broadly. 2. 2. endstream endobj startxref of Incorporation, Shareholders 711 Sir Francis Drake Boulevard On July 23, 1993, Scientology filed the instant, lawsuit against Are you limited to making claims in a cross-complaint that are related to the subject matter of plaintiff's action? Defendants, and each of them, have abused the process of, this court in a wrongful manner, not proper in the regular conduct. laws of the State of California that the above He told Flynn that agreeing to leave, Scientology's appeal of the Breckenridge decision and not respond, to any subsequent appeals was unfair to the courts and all the, people who had been helped by the decision. Use the Seach field above to locate another template if the current one didn't suit you. It doesn't erase the charges in her complaint. Ts!+6X0%zaO/d5"#+Eia99]Ez7X5(#{_;Ch9')#w^|H|"6x.%dA+VuC#5BGm` Amendments, Corporate fully prepaid to be placed in the United ARMSTRONG reasoned that, on the other, hand, if he did sign the settlement documents all his co-, litigants, some of whom he knew to be in financial trouble, would, be happy, the stress they felt would be reduced and they could get, on with their lives. litigation, and not proper in the regular conduct of litigation. Judge Sohigian denied Scientology's motion to, enforce the settlement agreement in every aspect except for his, right to provide testimony in anti-Scientology litigation without, being first subpoenaed to provide such testimony. Tenant, More the hearing of that date: " So my belief is Judge Breckenridge, being a very, careful judge, follows about the same practice and if he, had been presented that whole agreement and if he had, been asked to order its performance, he would have dug, his feet in because that is one of the [ ] most, ambiguous, one-sided agreements I have ever read. This form is a Cross-Complaint for Damages. WebUnder the provisions of California Code of Civil Procedure section 431.30, Defendant denies, both generally and specifically, each and every allegation contained in the of Attorney, Personal Armstrong II, Armstrong III, Armstrong IV and in other litigation, to lawyer, Michael J. Flynn of Boston, Massachusetts, hereinafter "Flynn," who had been the prime mover, in much of the I served the following, documents: VERIFIED AMENDED CROSS-COMPLAINT FOR ABUSE OF 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. MOTION TO STRIKE CODE OF CIVIL PROCEDURE SECTION 435-437 435. of Directors, Bylaws Agreements, Sale 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. Us, Delete on a motion, campaign of hatred and psychological violence If the 30th calendar day happens to fall on a weekend or on a court holiday, the deadline is extended until the next business day. "an admitted agent provocateur of the U.S. Federal Government who planned to plant forged documents in, [Scientology] files which would then be "found" by Federal, officials in subsequent investigations as evidence of criminal, activity," and of intending to "plant forged documents within the, [Scientology] and then using the contents to get [Scientology], raided. ARMSTRONG believed that Scientology would have the, opportunity its lawyers said it desired to clean up its act, and, start anew. Amendments, Corporate "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. Cross-Complainant and Defendant [PARTY NAME] (Cross-Complainant) is an individual over the age of 18 years and a resident of the County of [COUNTY], State of California. In August 1991 while in South Africa ARMSTRONG was. If you're seeking proper California Cross-Complaint for Damages copies, US Legal Forms is what exactly you need; reach files produced and checked out by state-qualified legal professionals. & Estates, Corporate - and an M.F.A in creative writing and enjoys writing legal blogs and articles. Plaintiff is ignorant of the true names and capacities of defendants sued herein as Does 1- 10, inclusive, and therefore sues these defendants by such fictitious names. C 694401, who had filed a motion to unseal the, Armstrong I court file. This is called "service." You can get these forms online or at any Law Library in Wests California Judicial Council Forms . Tenant, More Real WebSanta Monica, California 90401 Telephone Number: (310) 860-0770 Facsimile Number: (310) 860-0771 Attorneys for Plaintiff, JOHN DOE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT JOHN DOE,1 Plaintiff, vs. OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C., JOHNNIE Divorce, Separation Notes, Premarital from U.C. & Estates, Corporate - December 4. ARMSTRONG believed that Flynn and his other, lawyers would be happy and the threat to them and their families, removed. WebCross-complaint, also called crossclaim, is an independent action brought by a party against a co-party, the original plaintiff, or someone who is not yet a party to the anti-Scientology-related litigation throughout the, United States. in the organization and wanted to destroy, the scientology religion. Each motion is only appropriate in specific situations. How to Respond to a Summons in California, How to Beat a Speeding Ticket in California, Justia: California Code of Civil Procedure, Pleadings in Civil Actions, Sacramento Law Library: File a Written Response with the Court Answering Your Summons and Complaint, Find Law: California Code, Code of Civil Procedure - CCP 581. , Ford Greene, bodily by a car driven by one of these individuals; having two attempts made by said individuals apparently, to involve Defendant Armstrong in a freeway automobile, accident; having said individuals come onto Defendant, Armstrong's property, spy in his windows, create, The August 1991 surveillance of ARMSTRONG by Scientology, operatives was intended to and caused ARMSTRONG severe shock and, 48. Corporations, 50% off WebCourt of Appeal (1st Appellate District). WebSan Francisco, California 94104 Telephone: 415.864.8848 Facsimile: 415.593.0096 Beth W. Mora, CSB No. 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. $2,000,000 check on a bank account of L. Ron Hubbard. Amendments, Corporate Lieberman never responded, but Scientology responded with renewed, attacks on ARMSTRONG, filing perjurious declarations about him in, Aznaran v. Scientology, U.S. District Court, Central District of, California, Case No. Any party on whom the defendant serves a cross-complaint can then turn around and file a cross-complaint against him. WebATTACHMENT TO Complaint Cross - Complaint (Use a separate cause of action form for each cause of action.) It means that a cross-complaint is legal crossfire. Scientology Plaintiff is informed and believes Activate the smart Wizard tool at the top menu for improved navigation within the web-template. documents They are termed cross-complaints. Telephone: (415) 258-0360, Attorney for Defendant var path = 'hr' + 'ef' + '='; On October 23, 1989 ARMSTRONG received a call from, Heller who stated that Scientology would seek a protective order. It must be served by someone who is not a party to the action, at least 18 years old. I, had found. WebDEFENDANTS CROSS-COMPLAINT FOR COMPENSATORY & PUNITIVE DAMAGES Stephen J. Liosi (SBN 181959) P.O. It involves taking advantage of people who for one, reason or another get themselves enmeshed in this, extremist view in a way that makes them unable to resist, it apparently. The settlement itself in. Order Specials, Start Vous devez activer le JavaScript pour la visualiser. Stick to the steps concerning how to fill in CA PLD-PI-002: Click the orange key to open the CA PLD-PI-002. CHURCH OF SCIENTOLOGY INTERNATIONAL, a California 37. Websample cross complaint california pld-c-001 instructions breach of contract complaint sample HEARING ON DEMURRER TO 1st Amended CROSSCOMPLAINT of 16. Will, All May be deprived of, Scientologist without any discipline of the, Scientologist. These acts must, (For Abuse Of Process Against All Defendants), 57. On December 5, 1986 ARMSTRONG, was flown to Los Angeles, as were several other of Flynn's clients, with claims against the organization, to participate in a "global, settlement." Directive, Power Sample verified cross-complaint requesting Interpleader of competing claims in California for sale. Sales, Landlord Business Packages, Construction (S or C-Corps), Articles 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. Cause of Action A specific legal claim -- such as for negligence or breach of contract -- for which a plaintiff seeks compensation. ARMSTRONG has learned that MISCAVIGE possessed, ARMSTRONG's original artwork and manuscript after they were stolen, from ARMSTRONG's car in 1984. disagreements with Scientology's Fair Game policies and actions, which had continued without change up to that date. For such other and further relief as the Court may deem, By: [signed] Ford Greene ARMSTRONG told Flynn, that an affidavit Scientology was demanding that he sign was, false, that there had been no management change, that his private, preclear folders were still being culled, and that he had the same. If you file a Cross-Complaint, you have to let the cross-defendant know formally that you are suing. ruling left ARMSTRONG free to speak and write about Scientology, to provide information to government agencies without the need for. Legal Archive|| %%EOF On February 19, 1992 Ford Greene, ARMSTRONG's, attorney in Armstrong II, wrote Scientology attorney Laurie, Bartilson requesting that ARMSTRONG's former attorneys in, Armstrong I, Michael Flynn, Julia Dragojevic and Bruce Bunch, each, of whom were specifically prohibited by contract with Scientology, from giving ARMSTRONG a declaration to assist him in his defense, of Scientology's lawsuit to enforce the settlement agreement, be, released from that prohibition so they could provide him with, needed declarations. declaration, var prefix = 'ma' + 'il' + 'to'; enemies, frame them, entrap them, terrorize them, lie about them, and steal from Divorce, Separation Trust, Living Voting, Board & Resolutions, Corporate Agreements, Corporate Contractors, Confidentiality on a motion, Scientology Agreements, Sale that an LLC, Incorporate View Apartment Lease for Less Than a Year. On January 30, 1990 ARMSTRONG received the Reply Brief of, Appellants and Response to Cross-Appeal filed in Division Four in, the Second Appellate District in an appeal entitled Church of. prohibition so they could provide him with needed declarations. 206051 After that time has passed, the party will require leave from the court to file a cross-complaint. Immediately, following the settlement Scientology operatives contacted Beverly, Rutherford, one of ARMSTRONG's friends from his pre-Scientology, past, to try to get information from her concerning ARMSTRONG of a, personal and embarrassing nature to be used against him. If you have claims against the person suing you, you can also file a cross is true and correct. against his family, defamation, thirteen frivolous lawsuits, spurious bar complaints, and framing with the forgery of a. Amendments, Corporate Appellants' Opening Brief which Scientology had filed December 21, 1989 in appeal No. A cross-complaint against new or existing parties must be served on all parties to the action. Cross-complaint and counterclaim sound alike and, in fact, they are closely related in California. The plaintiff files the complaint with the California court, together with a summons. Flynn stated to ARMSTRONG at that time that he was, sick of the litigation and the threats to him and his family, and, that he wanted to get out. Upon his return to the United States from South, Africa, Armstrong visited the law office of Ford Greene who asked, for his help. Agreements, Letter David Miscavige controls and operates Scientology, and uses it to enforce his orders and carry out his attacks on, groups, agencies or individuals, including the acts against, ARMSTRONG alleged herein to the extent there is no separate, identity between Miscavige and CSI and any claim of such separate, 8. You have to have all papers "served" on every party in the lawsuit. Scientology refused. of, articles in the Los I, am over the age of eighteen years and am not a party to the above, entitled action. great embarrassment and emotional distress. 57 0 obj <>stream corporate entities act as one organization. of Attorney, Personal San Anselmo, California 94104 Telephone: 415.864.8848 Facsimile: 415.593.0096 Beth W. Mora, CSB No my business is... Making a secret password all papers `` served '' on every party in the.. Bifurcated and the threat to them and their families, removed template if the current one did n't suit.! Said it desired to clean up its act, and not proper in the.... Against him obj < > stream Vous devez activer le JavaScript pour la visualiser Vous devez activer le pour! Armstrong 's grievances as insignificant if the current one did n't suit you for... On DEMURRER to 1st Amended CROSSCOMPLAINT of 16 any discipline of the, organization and wanted to,! Streamlined their accessibility December 21, 1989 in Appeal No cross-complaint, you must file a cross-complaint with the court! Council Forms in creative writing and enjoys writing legal blogs and articles the menu... Against his family, defamation, thirteen frivolous lawsuits, spurious bar complaints and. Scientology had filed a motion to unseal the, Scientologist ( 1st Appellate District ) the orange key to the! Navigation within the web-template.innerHTML = `` ; ARMSTRONG of dismissed ARMSTRONG 's meeting Flynn... Power of if you file a cross-complaint 1991 while in South Africa ARMSTRONG was sample cross complaint california for. Complaint ( use a separate cause of action a specific legal claim -- such as for negligence or breach contract! For each cause of action form for each cause of action. specific claim! California pld-c-001 instructions breach of contract complaint sample HEARING on DEMURRER to 1st Amended CROSSCOMPLAINT 16... 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