I, Kendrick L. Moxon, hereby declare and state:
1. I am an attorney licensed to practice law in the State of California and the District of Columbia. I make the instant declaration of my own personal knowledge, and if called to testify thereto, I could and would do so competently.
2. I have spoken to Joseph Yanny hundreds of times since 1986 when I first met him, and have worked with him on several legal matters. I was counsel of record for the plaintiffs in the case of Religious Technology Center, et al. v. Yanny, et al., L.A.S.C. No. C690211.
3. I am also counsel of record for plaintiff in the case of Church of Scientology of California v. Gerald Armstrong, L.A.S.C. No. C420153. I have seen Armstrong in court four or five times over the past few years.
4. On July 15, 1991, I was at the clerk’s office in the United States District Court for the Central District of California. While there, at approximately 2:30 p.m., I saw Yanny in the office, and we said hello to each other. A few minutes later, I saw Yanny and Armstrong standing together in a corridor of the clerk’s office, between the area of the filing windows and the files storage space. I walked up to Armstrong, and said to him, “Does Yanny represent you, too?” Armstrong nodded his head in assent and at the same time Yanny said “No.” 5. I said to Armstrong, “You say yes and Yanny says no.” Yanny interrupted Armstrong’s response, and said, “I represent him only on literary matters.” I stated to Armstrong, “Do you know who I am?” Armstrong said “No.” I said, “I’m Rick Moxon,”
and held out my hand. He said, “Gerry Armstrong” and shook my hand. I said to Armstrong, “Scientology literary matters?”
Yanny pulled Armstrong away by the arm, and said, “Talk to his lawyer.”
6. About a minute later, I went into the files area of the clerk’s office, and saw Yanny and Armstrong together looking at a court file. I went over to them, and asked Yanny what they were reading. Yanny said “J.J. Gaw v. IRS. Very interesting. Very interesting.” J.J. Gaw is a private investigator I have retained to conduct investigations on behalf of the Church of Scientology International. I asked Yanny if he has sent me service of a paper about which he had called me last week. He responded and I left the area.
7. Just before 3:00 p.m., I returned to the clerk’s office and spoke to several of the filing window clerks to verify what file Yanny and Armstrong were reviewing. I confirmed that with a stack of files in the clerk’s area which was being returned to the shelves after review by a requestor, was a copy of the Gaw case, No. 91-1906 JSL. I confirmed this by asking.the clerk to see if the file was present. He stated that it was and brought the file over to the desk for me to see.
I declare under penalty of perjury that the foregoing is true and correct. Signed this 18th day of July 1991, in Los Angeles, California.
[signed] Kendrick Moxon