In Church of Scientology v. Armstrong (1991) 232 Cal.App.3d 1060, a church and a former member settled their dispute at the end of the case-in-chief by stipulating that all court records would be returned to the church and the court files sealed from public view. Following the settlement, a litigant in another case against the church convinced the trial judge's successor to unseal the records. On the church's appeal, the Court of Appeal reversed, holding that too much time had passed "and the parties had the right to rely on the sealing order." (Scientology, supra, 232 Cal.App.3d at pp. 1069-1070.) The Court found the defendant was privileged or justified (see Rest.2d Torts, 261) when he delivered the organization's documents to his attorney because "he believed that his life, physical and mental well-being, as well as that of his wife . . . were threatened" by the organization. ( Church of Scientology v. Armstrong, supra, 232 Cal. App. 3d at p. 1073.) There was substantial evidence the organization had threatened him physically. The court recognized "Armstrong's defense was predicated on his claim that he reasonably believed the Church intended to cause him harm, and that he could prevent the apprehended harm only by taking the documents, even though the taking resulted in harm to the Church." (Ibid.) Church of Scientology did say this in a footnote: "The plaintiffs also urge, based on cases which are inapposite to that at bench, that the justification defense applies only in emergency situations requiring immediate action to avert danger, or where the agent believes that the principal's documents are the fruits or instrumentalities of crime or fraud." ( Church of Scientology v. Armstrong, supra, 232 Cal. App. 3d at p. 1072, fn. 6.)