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SETTLEMENT AGREEMENT
A. PRIOR SETTLEMENTS:
Settlement agreements made prior to
November 1,
1986 and prior to the collective settlement
are stated below:
| Client
|
Amount
|
Fee and
Expenses
|
|
(1) Bears
|
$115,000.00
|
To be determined
with local counsel |
| (2) Garritys |
$175,000.00
|
To be determined
with local counsel |
| (3) Petersons |
$175,000.00
|
To be determined
with local counsel |
| (4) Jefferson |
$150,000.00
|
To be determined
with local counsel |
| (5) Lockwood |
$150,000.00
|
To be determined
with local counsel |
| (6) Hartwell |
$150,000.00
_______________ |
To be determined
with local counsel
_______________ |
| |
$915,000.00
|
To be determined
with local counsel |
B. INDEPENDENT SETTLEMENT:
The Christofferson-Titchborne settlement
was made
separate from the collective settlement. It
was agreed to
between attorney Gary McMurray, his client,
Julie
Christofferson-Titchborne and the Church of
Scientology.
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| Client
|
Amount
|
Fee and
Expenses
|
|
Christofferson-
Titchborne
|
$100,000.00
|
To be determined
by attorney
McMurray and
client. None of
the attorneys
representing other
clients in the
collective settle-
ment represent or
have represented
Christofferson-
Titchborne. |
C. COLLECTIVE SETTLEMENT:
The following cases/clients are part of a
collec-
tive settlement made on December 11 ,
1986. The undersigned
acknowledge that the settlement set forth
above in Para-
graphs A and B were made as separate
settlements, meaning
that the cases/clients listed in Paragraphs A
and B agreed
to the amounts stated therein prior to the
collective
settlement as in Paragraph A, and independent
from the
collective settlement as in Paragraph B. The
total amount
of the collective settlement is $2,800,000.00.
The total
amount of the collective settlement and the
prior inde-
pendent settlements in Paragraphs A and B is
$3,815,000.00.
The collective settlement allocation is as
follows:
| Client
|
Amount
|
Fee and
Expenses
|
|
(1) Nancy Dincalci
|
$ 7,500.00
|
None |
| (2) Kima Douglas |
$ 7,500.00
|
None |
| [HW][Michael Douglas] |
[HW][$7,500.00]
|
[None] |
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|
(3) Robert Dardano
|
$ 15,000.00
|
None |
| (4) Warren Friske |
$ 15,000.00
|
None |
| (5) William Franks |
$ 40,000.00
|
None |
| (6) Laurel Sullivan |
$ 40,000.00
|
None |
| (7) Edward Walters |
$ 100,000.00
|
To be determined
between client and
attorneys |
| (8) Howard Schomer |
$ 200,000.00
|
To be determined
between attorney
Bunch and client |
| (9) Martin Samuels |
$ 500,000.00
|
To be determined
between attorney
McMurray and
client |
(10) Gerald Armstrong
v. Church of
Scientology |
$ 800,000.00
|
To be determined
between attorney
Bunch and client |
(11) Fees and expenses
to attorneys
Contos & Bunch,
Robert Kilbourne,
Michael Flynn, and
associated counsel
for the prosecution
and defense of various
cases including the
"Hubbard documents"
case, the "check-
frame up" case and
the defense of
approximately 17
lawsuits against
attorney Flynn and
his clients. |
$ 500,000.00
|
To be determined
between attorneys
Contos & Bunch,
Michael Flynn,
Robert Kilbourne,
and associated
counsel |
(12) Flynn v. Ingram
(No. __________ )
Flynn v. Hubbard
(No. __________ )
|
$ 575,000.00
-0-
_______________ |
To be determined
between attorney
Flynn and his
counsel |
| |
$ 2,800,000.00
|
|
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We, the undersigned, agree and acknowledge
that
(1) we have read the foregoing Settlement
Agreement;
(2) that we agree with the total settlement
amount and the
allocations to the respective cases/clients as
set forth
therein; (3) that we have either consulted,
been advised to
consult or have had the opportunity to consult
with
attorneys other than Michael J. Flynn who, we
acknowledge is
also a claimant against the Church of
Scientology and L. Ron
Hubbard; (4) that we agree to maintain the
confidentiality
of this Settlement Agreement; (5) that we
acknowledge that
many of the cases/clients involved in this
settlement have
been in litigation against the Church of
Scientology for
more than six to seven years, that many have
been subjected
to intense, and prolonged harassment by the
Church of
Scientology throughout the litigation, and
that the value of
the respective claims stated therein is
measured in part by
the (a) length and degree of harassment; (b)
length and
degree of involvement in the litigation; (c)
the individual
nature of each respective claim in connection
with either
their involvement with the Church of
Scientology as a member
and/or as a litigant; (d) the unique value of
each
case/client based on a variety of things
including, but not
limited to, the current procedural posture of
a case,
specific facts unique to each case, and
financial, emotional
or consequential damage in each case; that we
agree and
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acknowledge that Michael J. Flynn has
primarily been
responsible for bearing the cost of the
litigation over a
period of approximately seven years, that he
or his firm's
members have been required to defend
approximately 17
lawsuits and/or civil/criminal contempt
actions instituted
by the Church of Scientology against him, his
associates and
clients, that he and his family have been
subjected to
intense and prolonged harassment, and that his
claims
against the Church of Scientology and L. Ron
Hubbard, and
his participation as an attorney have a unique
value which
is accurately and properly reflected in the
allocations set
forth herein.
[signed] NANCY
DINCALCI
NANCY DINCALCI |
DATE:
Dec 5, 1986 |
[signed] KIMA DOUGLAS
KIMA DOUGLAS |
DATE: Dec 5
- 1986 |
[signed] ROBERT DARDANO
ROBERT DARDANO |
DATE:
Dec-20-1986 |
______________________________
WARREN FRISKE |
DATE: __________ |
[signed] LAUREL SULLIVAN
LAUREL SULLIVAN |
DATE: Dec ,
1986 |
[signed] MICHAEL DOUGLAS
[HW] MICHAEL DOUGLAS |
DATE: Dec 5,
1986 |
[signed] Julie Christofferson
Titchbourne
[HW] Julie Christofferson Titchbourne |
DATE: Dec 6,
1986 |
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[HW]______________________________
CAROL GARRITY |
DATE: ____________________ |
[HW]______________________________
Paul Garrity |
DATE: ____________________ |
[signed] WILLIAM
FRANKS
WILLIAM FRANKS |
DATE: [ illegible ] |
[signed] EDWARD WALTERS
EDWARD WALTERS |
DATE:
December 7th, 1986 |
[signed] HOWARD SCHOMER
HOWARD SCHOMER |
DATE:
12-5-86 |
[signed] MARTIN SAMUELS
MARTIN SAMUELS |
DATE: Dec.
4, 1986 |
[signed] G. ARMSTRONG
GERALD ARMSTRONG |
DATE:
12-6-86 |
______________________________
MICHAEL J. FLYNN |
DATE: ____________________
|
CONTOS & BUNCH
A PROFESSIONAL CORPORATION |
|
By:[signed] JULIA DRAGOJEVIC
BRUCE M. BUNCH
[HW] JULIA DRAGOJEVIC |
DATE:
12-10-86 |
[signed] GARRY P. MC MURRY
GARY MC MURRAY |
DATE:
December 6, 1986 |
______________________________
ROBERT KILBOURNE |
DATE: ____________________ |
______________________________
[HW] JANE Peterson |
DATE: ____________________ |
______________________________
[HW] Richard Peterson |
DATE: ____________________ |
[signed][ illegible ]
[HW] illegible |
DATE: [illegible] |
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