DeCrescenzo Vs Scientology Kathryn Saldana Declaration Ocr

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.WP\CASES\9527\SUM-JUDG\Oeclarations\2013 10-9 Saldana Decl.wpd
BLUMBERG LAW CORPORATION
JOHN P. BLUMBERG, ESQ. (SBN 70200)
SINDEE M. SMOLOWITZ, ESQ. (SBN 123237)
444 W. OCEAN BLVD., SUITE 1500
LONG BEACH, CA 90802
TELEPHONE : ( 5 6 2 ) 4 3 7 - 0 4 0 3
TELECOPIER: ( 562) 432- 0107
METZGER LAW GROUP
A PROFESSIONAL LAW CORPORATION
RAPHAEL METZGER, ESQ. (SBN 116020)
KATHRYN SALDANA, ESQ. (SBN 251364)
401 E. OCEAN BLVD., SUITE 800
LONG BEACH, CA 90802-4966
TELEPHONE: (562) 437-4499
TELECOPIER: ( 562) 436-1561
Attorneys for Plaintiff
LAURA ANN DECRESCENZO
FILED
LOS ANGELES SUPERIOR COURT
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
LAURA ANN DeCRESCENZO, aka
LAURA A. DIECKMAN,
Plaintiffs,
vs.
CHURCH OF SCIENTOLOGY
INTERNATIONAL, a corporate
entity, AND DOES 1 - 20,
Defendants.
CASE NO. BC411018
Assigned to the Honorable
Ronald M. Sohigian, Dept. 41
DECLARATION OF KATHRYN SALDANA
IN SUPPORT OF PLAINTIFF'S
OPPOSITION TO DEFENDANTS' JOINT
MOTION FOR SUMMARY JUDGMENT ON
THE GROUND THAT THE STATUTES OF
LIMITATIONS BAR THE ACTION
DATE:
TIME:
DEPT:
October 23, 2013
8:30 a.m.
41
DECLARATION OF KATHRYN SALDANA IN SUPPORT OF PLAINTIFF'S
OPPOSITION TO DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE
GROUND THAT THE STATUTES OF LIMITATIONS BAR THE ACTION
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.WP\CASES\9527\SUM-JUDG\Declarations\2013-10-9 Saldana Decl.wpd
DECLARATION OF KATHRYN SALDANA
I, Kathryn Saldana, declare as follows:
1. I am an attorney at law, duly licensed and authorized to practice law in the State
of California.
2. Unless the context indicates otherwise, I have personal knowledge of the matters
set forth hereinafter and, if called as a witness, I would competently testify thereto.
3. I am employed as an associate attorney at the. Metzger Law Group, counsel for
Plaintiff, Laura DeCrescenzo (aka Dieckman), in this action.
4. Attached hereto as Exhibit "1" are true and correct copies of portions of the
transcript of the deposition of Laura Dieckman taken in the case of Claire Headley v. Church of
Scientology International, et al., Case No. CV09-3987 DSF (MANx).
transcript of the deposition of Laura Dieckman taken in this action on May 1, 2012.
6. Attached hereto as Exhibit "3" are true and correct copies of the transcript of
the deposition of Laura Dieckman taken iri. this action on May 2, 2012.
the deposition of Laura Dieckman taken in this action on May 3, 2012.
the deposition of Laura Dieckman taken in this action on July 17, 2012.
transcript of the deposition of Kelly Forrest taken in this action on July 20, 2012.
transcript of the deposition of Stephanie Bauer taken in this action on July 19, 2012.
transcript of the deposition of Claire Headley taken in Claire Headley v. Church of Scientology
International, et al., Case No. CV09-3987 DSF (MANx), on November 4, 2009.
1
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------
e .WP\CASES\9527\SUM-JUDG\Declarations\2013-10-9- Saldana Decl.wpd
transcript of the deposition of Astra Woodcraft taken in Claire Headley v. Church of Scientology
International, et al., Case No. CV09-3987 DSF (MANx)"on January 28, 2010.
13. Attached hereto as Exhibit "10" is a true and correct copy of the Court of
Appeal's opinion, dated June 24, 2011.
transcript of the deposition of Stace Dieckman taken in this matter on July 19, 2012.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Executed October 9, 2013, at Long
Ka hryn Saldana
2

EXHIBIT 1
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
MARC HEADLEY, )
)
Plaintiff, )
)
vs. ) CASE No. CV09
) -3986DSF(MANx)
CHURCH OF SCIENTOLOGY )
)
INTERNATIONAL, a corporate )
)
entity, and DOES 1-20, )
.)
Defendants. )
_______________ )
VIDEOTAPED DEPOSITION OF LAURA ANN DIECKMAN
Los Angeles, California
Monday, February 1, 2010
Reported by: Wendy S. Schreiber
CSR No. 3558
NDS Job No.: 135318
'.-
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Page 98
1 I got pregnant, there was still some question as.to
2 what would -- you know, like -- but then I was told,
3 no, if you do, you will be off-loaded. I did not
4 the issue as far as I know I do not remember when it
12:07:34 5
came out exactly but I don't yeah, I don't -- I
6 don't know.
7
Q. So when you got married there was -- I'm
8 sorry, when you got married, you said you were aware
9 that there was an imminent -- it hadn't completely
12:07:51 10
changed but there was a change coming in the rules
11 and regulations that --
12
A. I didn't think about it until I was
13 pregnant, so I couldn't tell you at the time I was
14 married if I knew it was imminent.
12:08:02 15
Q. And if. I'm understanding you correctly, at
16 the time that you.became pregnant there was
17 apparently some uncertainty about what the
10 applicable rule was?
19
A. There was uncertainty in my head. When I
12:08:14 20
said to the people in the organization that I was
21
pregnant, I was told that in the case of me keeping
22
the baby I would be off-loaded.

23
Q. And so after you became pregnant, with whom
24
did you first speak? Did you talk to your husband?
12:08:29
25
Did you talk to people in the organization?
"'I
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Page 99
1
A.
I found out that I was pregnant at a little
2
clinic that I had gone to a couple of times and I
3
got back to the HGB with a ride from someone from my
4
org and when I got there, I called Jesse.
12:08:53 5
Q. Where was Jesse posted?
'
6
A. He was posted in the blue building, but he
7
was in CMO PAC, Pacific Area Command. Yeah, I
8
called him and told him first.
9
Q.
Did you and Jesse talk then about whether to
12:09:13 10 keep the baby or to abort?
11
A. Aborting was not something that was in my
12 head.
13
Q. So you told Jesse at that point you wanted
14 to keep the baby?
12:09:21 15
A. Yes.
16 MR. VAN SICKLE: Object.
17 BY MR. BRODY:
18
Q. And at the time that you had this
19 conversation with Jesse did you have an
12:09:29 20 understanding of what was the applicable rule in
21 terms of whether you could have the baby and go to a
. ~ ... '
22
Class V org or something else?
23 MR. VAN SICKLE:. Object to the form of the
24
question.
rr..2 12:09:40
25 THE WITNESS: I told you a minute ago that
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Page 100
1 when I found out I was pregnant there -- I didn't
2 know for sure what they were going to say, if they
3 were going to say the Class V org thing or the
4
off-loading thing, because of I don't think the
12:09:58 5
issue had actually come up yet. Maybe I'm wrong
6 about that, maybe I hadn't seen it, but there was a
7 question in my mind I do remember that.
8 BY MR. BRODY:
9
Q. So you told Jesse that you would like to
12: 10: 10 10
keep -- no question you were going to keep the baby?
11
A. Yes.
12
Q. What did Jesse say?
13
A. He was freaked out.
14
Q. What did he say?
12:10:21 15
A. I don't remember off the top of my head what
16 his first reaction was because that wasn't -- that
17 isn't the thing that sticks out in my head about the
18 whole thing.
19
Q. Okay.
12:10:34 20
A. I know that --
21
Q. So you've told me all you can remember
22
about --
23
A. No.
24
MR. VAN SICKLE: She's still answering the
'" (
. ...,..
12:10:40
question.
25

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Page 101
1
MR. BRODY: I didn't know that.
2
THE WITNESS: I told him and I know that he
3 had a concern about how were we going to -- I just
4 don't remember the certain terms of the sequence of
12:10:56 5
events of things that happened because the things
6 that stand out in my head are being in the
7 Commanding Officer's office, which was Gabriella
s Saccomanno, being in her office and talking to her
9 about it.
12:11:15 10
BY MR. BRODY:
11
Q. Let me just stop because I'm just .trying to
12 get this in some sequence to the extent that you can
13 remember it. You've told me the best you can about
14 what you and Jesse talked about when you called-
12:11:26 15
Jesse and told him you had learned you were
16 pregnant; is that correct?
17
MR. VAN SICKLE: Object to the form of the
18 question. Argumentative and misstates the
19 testimony.
12:11:32 20
THE WITNESS: I don't remember everything
jl"''
21 that happened in the conversation with Jesse. I

22 knew that we were going to go talk to our applicable
"'
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23 people in the organization because we needed to say,
1,L
....
24 yeah, we were pregnant. We were going to have a
!'-.. 12: 11 :.44
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25 baby.
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Page 102
1 BY MR. BRODY:
2
Q. Okay.
3
A. At that point then we went and spoke to the
4 applicable people. For some reason I don't know why
12:11:51 5
the applicable people were the cos at the time and I
6 don't -- I don't know if there were other people
7 that could have been spoken to, but that's who we
a went to.
9
Q. So when you say the co, that's the
12:12:00 10
Commanding Office of each of your respective
11 organizations?
12
A. Yes.
13
Q. So you went to speak to the co of the CMO
14
A. I-X-U.
12:12:13 15
Q. Yeah. Thank you. And you told me that was
16 Gabriel?
17
A. Gabriella Saccomanno.
18
Q. And did you go speak with Gabriella shortly
19 after you learned that you were pregnant?
12:12:25 20
A. Yeah, within -- within 30 minutes of getting
21 back to the HGB.
22
Q. Anyone else present when you spoke with
23
Gabriella?
24
A. No.
"'
\. 12: 12: 3 8
25
Q. You met with her in her office?
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Page 103
1
A. Yes.
2
Q. Tell me what you recall saying to her and
3 what she said to you.
4
A. I told her that I was pregnant. She said,
12:12:51 5
"What do you want to do?"
6
I said, "There's no question in my mind.
7 I'm going to have the baby." I was there to talk to
B her about what would happen. I was asking her, "So
9 what happens when this happens? What do we do?"
12:13:11 10
And at that point she told me -- she said,
11
11
Laura, I 'm going to te.11 you something. Nobody
12 else really knows about this but I'm going to tell
13 you. A few months ago I found out that I was
14 pregnant." She said that she had actually been
12:13:33 15
about 15, 16 weeks' pregnant when she found out she
16 was pregnant. And she said, "And I had a thought go
17 through my head of what's the greatest good for the
10 greatest number of dynamics?" And she said,
11
I went
19 straight to a place called Family Planning
12:13:54 20
Associates and set up a date to have an abortion."
21
And I was like, "Okay, why are you telling
22
me this?" And I -- and then we got Chris Cole who
:,__
23
is
24
Q. Let me stop you because we're getting short
12: 14 : 14
t:, r
25
of tape time. Have you told me everything you can

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Page 104
1 remember about your conversation with Gabriella
2 before Chris Cole came into the room or joined the
3 conversation ~ should say?
4
I don't know. She told me about that and
12:14:34 5
she said, "You know, it really wasn't even a
6 thought." Like the thought went through her head
7 really fast of, you know, what am I going to do here
8 and she told me that it was -- she went down there
9 and set up the appointment and it was a two-day
12:14:49 10
procedure because she had been so far along in the
11
pregnancy.
12
I was like, "How did you not know you were
13
pregnant?"
14
And she said she had had early physical
12:14:59 15
problems that she didn't recognize the fact that she
16 was pregnant. And -- yeah, that's -- and then she
17 said, "Well /. what does Jesse want to do?"
18
And I said, "We're going to have the baby.
19 There's no question about it."
12:15:18 20
And she said, "Okay, well let's call them,"
21
and they got on the phone and then that's --
22
Q. Okay, let me stop you there because we're
23
just about out of time. So let's take a short break
24
for a tape .change and then we can resume.
~ - . ! 12:15:32 25
VIDEO OPERATOR: This marks the end of
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Page 10s
1 videotape No. 1, Volume 1, in the deposition of
2 Laura Ann Dieckman. Going off the record. The time
3
is 12:15 p.m.
4 (Brief recess.)
12:24:23 5 VIDEO OPERATOR: This is the beginning of
6 videotape No. 2, Volume 1, in the deposition of
7 Laura Ann Dieckman. The time is 12:24 p.m.
8
BY MR. BRODY:
9 Q. We're back on the record. How are you?
12:24:39 10
A. Fine. Thank you.
11
Q. Any reason we can't proceed?
12
A. No.
13 Q. We were talking about the conversation with
14
Gabriella and then, as I understand it, then you
12:24:50 15 spoke then with Jesse and his CO. Before we do
16
that, I wanted to back up a little bit and get some
17
more background on what was going on at the time.
-
18 How old were you when you learned that you
19
were pregnant?
12:25:02 20
A. 17.
21
Q. And at the time were you practicing birth
22
control with your husband?
23
A. I had wanted to have a kid and I stopped
24
taking the pill.
12:25:20 25
Q. When did you stop taking the pill?.

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1
A. Right after Christmas in 2005.
2
Q. Was this something you discussed with Jesse?
3
A. No.
4
Q. Was this something you discussed with
5
anybody else?
6
A. No.
7
Q. So you stopped taking the pill, I take it,
B hoping that you would become pregnant?
9
A. Yes.
10
Q. At the time that you.stopped taking the pill
11 hoping to become pregnant, did you do anything to
12 check out then what were the applicable policies as
13 to what would occur if you had a child in terms of
14 your remaining in the Sea Org?
15
A. No.
16
Q. Was your understanding at that -- withdraw
17 that.
18 We talked about this some but let me ask you
19 this. So when you went off the pill intending to
20
get pregnant, what did you understand was the policy
21
that would come into play when you became pregnant
22
and then announced it?
23
A. I honestly didn't care. I wanted to have a
24
kid.
25
Q. And despite your -- I hear that. And
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Page 107
1 despite that indifference, can you tell me
2 nevertheless what you recall or believed the policy
3 was in February -- I'm sorry, Christmas of '95 when
4 you went off the pill?
12:26:31 5
6 question.
7
THE WITNESS: I've already said I don't
8 remember. I don't -- I know that there was an
9 uncertainty in terms of whether it would be to go to
12:26:40 10
a Class V or be off-loaded with a freeloader bill.
11 And when I told Jesse and after we had talked back
12 and forth -- if you want to go through it we can go
13 through it step by step -- but I told him that I
14 wanted to have the kid and I did make that extremely
12:26:58 15
clear.
16 BY MR. BRODY:
17
Q. Did you tell him that before you became
18 pregnant?
19
A. No.
12:27:01 20
Q. You told him after you were pregnant?
21
A. Yes.

22
Q. Was that during this call that you were
23
telling me about before the tape change that is
"
24
where you called him up and said I'm pregnant and so
t-.., 12:27:12 25
forth, or was it another conversation?
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Page 108
1
A. I told I mean, I repeated that several
2 times so ...
3
Q. So you told Jesse you were pregnant. I take
4 it he was surprised because, I take it, he thought
5
you were taking birth control pills?
6
A. Yes.
7
Q. And he said something to the effect of,
8 "Boy, Laura, I'm surprised because I thought you
9 were on the pill"?
10
A. He may have said that. He was definitely
11 surprised.
12
Q. Did you express concern about how are we
13 going to take care of a baby?
14
A. After we had spoken to our respective
15
people. Not at the first -- not at first.
16
Q. So that first conversation was more just I'm
11 surprised to hear you're pregnant and you say,
18 "Jesse" -- I take it you said -- did you tell him,
19 "Jesse, I went off the pill at Christmas"?
20
A. No, I did not tell him at that point.
21
Q. You told him later?
22
A. Yes.
23
Q. So yo.u just said, "We're having this baby."
24
You told me that before. That was the gist of what
25
you said at this time?
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Page 109
1
A. Yes.
2
Q. And.that's when you went to speak to your CO
3 and he went to speak to his CO; is that right?
4
A. Yes.
5
Q. Is there anything else? I know we talked
6 about having just had this little discussion does
7 that help refresh your recollection about anything
8 else you and Jesse said to each other in that call
9 when you first,told him you were pregnant?
10
A. I think that.'s pretty much it, yeah, in
11 terms of that first call.
12
Q. Did you have -- when you went off the pill
13 and the intention of becoming pregnant, did you have
14 any thought in your mind about what would happen
15
wherl you became pregnant?
16
A. I'd have a kid .. That's what people want to
17 get pregnant, they want a kid. I'm going to tell
18 you some.thing straightforward right now. I would
,.
19 never have joined the Sea Organization if I had been
20
told that I couldn't have kids. When _I joined the
21 Sea Organization, I specifically what.happens
22
if I -- when I have kids? I've always from the
23
beginning of my life always wanted children and I
24
said, "So what happens when you have kids?" And I
25
to"id my family and everybody when I was 12 years
"-:I J: :i
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1 old, okay, I will be back after I'm married -- I'd
2 come back to Albuquerque Org because at that time
3 the rule was you'd go to a Class V org when I have
4 kids and I said that when I joined the Sea
12:29:38 5
Organization.
6
So later on when I got pregnant -- and I
7 wanted kids. This came up -- you can -- and nobody
8 can hide this because it came up every year in my
9 Sea Org history after I was married that I wanted
12:29:51 10
kids and that what happened happened killed me
11 because I was made to abort a child that I wanted.
12
MR. BRODY: I'll object to everything after
13 "kid" and move to strike as nonresponsive.
14
MR. VAN SICKLE: You're kidding? That's
12:30:15 15
really bad taste. You know, that was responsive to
16 your question. What did you think about when you
17 had a child?
18
MR. BRODY: Do you want to stop for a
19 moment?
12:30:25 20
THE WITNESS: No, I don't. I think that's
21 bullshit.
22
MR. VAN SICKLE: I do, too. That was really
23
bullshit. A move to strike that question was
24
absolute bullshit.
12:30:33
25
THE WITNESS: I wanted to have a kid and I

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1 was told by somebody there that it was the greatest
2 good for greatest number of dynamics to have an
3 How is that right? How is that right to
4 a person to say aborting a child is the greatest
12:30:54 5
good for people? How is that right?
6 BY MR. BRODY:
7
Q. So --
8
MR. VAN SICKLE: They think they can have a
9 rule. You asked the question, "Oh, there's a rule
12:31:06 10
about babies?" What, that means she's not supposed
11 to have one? I don't think so.
12
MR. BRODY: There's no question pending so
13 now we have -- I understand the witness --
14
THE WITNESS: I'm still answering your
12:31:18 15
question.
16
MR. BRODY: I
17
A. That is my answer to your question.
18
Q. All right. Fine. Now, what I'm trying to
19 understand -- do you want to stop for a few moments?
12:31:28 20
A. No, I don't.
21 '
Q. I understand that when you went off the pill
22
with the.thought that you would become pregnant,
23
what you were thinking was you wanted to have a
24
child. But did you have any thought at that time
'
12:31:47 25
about, well, how will I care for the child? Where
iZ
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1 will I live?
2
A. When I was told that that would mean that
3 we'd be off-loaded, I was like, okay, we'll move
4 back to Albuquerque.where my family is. My parents
12:32:04 5
owned a business. Jesse could work for my parents.
6 If we wanted to stay in L.A., he could go work for
7 Survival Insurance where his dad worked. I had no
a question that no matter what I would make good and
9 raise a child. Was I scared? Absolutely. I had no
12:32:25 10
experience in life other than the Sea Org so when I
11 was told, okay, well, you're going to be off-loaded
12 with a bill and you have the threat of, you know --
13 you have to now start a new life because you don't
14 have the security of whatever you had joined into,
12:33:04 15
even though you were told one thing when you joined,
16 it's different now so you don't have a choice in
17 that. There's nothing you can do to change it.
18 Q. What I'm trying to understand, Ms. Dieckman,
19 is when you went off the pill around Christmastime
12:33:17 20
in '95, was it your understanding that if you became
21
pregnant as you intended to do that you would be
22
sent back to a Class V org like the Albuquerque?
'
23
24
question. That wasn't the question she was
...
12:33:31 25
answering.
!J.) Network Deposition Services, Inc. networkdepo.com 866-NET-DEPO
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"'I
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y .. _
1
Page 113
MR. BRODY: That was the question that I
2 asked.
3
MR. VAN SICKLE: No. You asked if she had
4 given any thought to if she could raise a child and
5
she was telling you her thoughts about whether she
6 was going to raise a child. She was answering your
7 question and you cut her off.
8
MR. BRODY: Fine.
9
Q. Now, do you have the question in mind that I
10
asked?
11 Would you read the question back for her,
12 please, Ms. Reporter.
13 (The pending question was read as follows:
14
"Q. What I'm trying to
15
understand, Ms. Dieckman, is when
16
you went off the pill around
17
Christmastime in '95, was it your
18
understanding that if you became
19
pregnant as you intended to do that
20
you would be sent back to a Class V
21
org like _the Albuquerque?")
22
THE WITNESS: I think I've answered this
23
question like three or four times now. I didn't
24
know. It was going to be either I was off-loaded or
25
I would go to a Class V and it didn't matter to
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1 me which ohe it was.
2 BY MR. BRODY:
3
Q. So to come back' now to your conversation
4 with Gabriella, we went about -- we went through the
12:34:39 5
first part. And I take it then that she ,telephoned
6 over to the blue building where your husband was or
7 co telephoned her?
8
A. One way or the other. I don't remember
9 which it was, but we were on the phone with them.
12:34:51 10
Q. Was it on a speaker phone?
11
A. Yes.
12
Q. Tell me who said what to whom.
13
A. I don't remember word for word. I do
14 remember I got so pissed at Chris -- her name was
12:35:04 15
Chris -- that I hung up on her.
16
Q. And Chris was Jesse's CO?
17
A. Yes.
18
Q. Tell me the gist the best you .can remember
19 of the conversation understanding you're nqt going
12:35:14 20
to remember word for word but tell me the best that
21
you can remember the conversation.
22
A. That I wasn't looking at what the greatest
23
good for the greatest number of dynamics was.
24
h:::
Q. And who was this who said that to you?
12:35:26 25
A. Chris. She was getting mad that I was
V
!';:
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1 saying that I was going to keep the baby and she was
2 telling me look at the effects that that's going to
3 have to the organization because you have both
4 these -- you guys are both holding these certain
12:35:43 5
jobs and how important they are and blah, blah,
6 blah. And I wasn't looking at that. And she was
7
telling me this. And I got I got so livid that I
8 physically picked up the phone and hung it up
9 because I was not interested in hearing such
12:36:04 10
bullshit.
11
Q. And do you remember any other part of the
12 conversation before you hung up the phone on Chris?
13
A. No, I don't.
14
Q. Do you remember -- okay. How long did the
12:36:27 15
conversation last before you -- withdraw that.
16 The conversation that included Chris -- and
17 I take it that Jesse was on the phone as well?
18
A. Yes.
19
Q. So how long did that portion of the
12:36:38 20
conversation where you've got Chris and Jesse on one
21
end and you and Gabriella on the other end, about
22
how long did that last?
'
23
A. I honestly couldn't tell you.
l,1
24
Q. And what happened after you hung up the

.y..,, 12:36:54
,( "'1

25
phone on Chris?
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1
A. I talked to Gabriella who was more the nice
2 guy type approach.
3
Q. What did you and Gabriella say to each
4 other?
12:37:14 5
A. I don't remember.
6
Q. Give me your best recollection. I
7 understand you won't remember word for word.
8
A. She just was like, "Chill, Laura. You know,
9
it's not ... " you know, and then she started going
12:37:27 10 in on the point of -- .in terms of the Scientology
11 jargon -- of there's no Thetan there yet, meaning
12 the baby was just -- she's telling me the baby is
13 just tissue at this point in time. It's not like a
14 big deal. She's basically saying that an abortion
12:37:53 15 is the right thing to do and that it wouldn't be
16 that big of a deal because it's not that far along
17 yet. And -- and then later --
18 Q. Have you told me all you can remember about
19 the conversation you had with Gabriella after you
12:38:21 20 hung up on Chris?
21
A. I don't remember.
22
Q. I understand. But have you told.me the best
23
that you can?
24.
A. Yes.
,v
25
Q. Okay. And then when was the next time you
:,
;;
1
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1 spoke with Jesse or anybody within a Scientology
2 organization about your pregnancy and keeping the
3 baby or not?
4
A. There's certain times that I remember. I
12:38:45 5
remember the next day. Obviously I talked to Jesse
6 about it that night and we had kind of come to the
7 conclusion that we were going to keep the baby.
8
Q. I take it you and Jesse shared quarters at
9 that time?
12:39:02 10
A. Yeah.
11
Q. Do you remember anything more specifically
12 about your conversation with Jesse that night? So
13 the gist was that Y.OU and Jesse talked about it and
14 you were going to keep the baby, right?
12:39:13 15
A. Yeah. And then the next morning I had
16 called the doctor that I had seen on -- I don't
17
remember her name Angie or something or
18 another -- and I was talking to her about things
19 about, you know -- questions I had about pregnancy.
12:39:31 20
I remember that. I was on the phone. And somebody
21
who is a friend of mine, Melissa Brown, had
22
overheard me talking and she came over and she's
23
like, "You' re pregnant?
11
24
Q. Where were you when you made this call to
k 12:39:43 25
the doctor?
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1
.MR. VAN SICKLE:' You didn't let her answer
2 the question again. She was still answering the
3 question.
4
MR. BRODY: I'm sorry, I just wanted to know
12:39:51 5
where it was.
6
MR. VAN SICKLE: Then when you ask the
7 question then she loses the tract and then you ask
a her if she's said everything she can remember.
9 BY MR. BRODY:
12:39:57 10
Q. Go ahead. I'm sorry.
11
A. I was on the phone in CMO IXU.
12
Q. Okay. And you say while you were on the
13 phone Melissa Brown overheard your conversation?
14
A. She heard a little bit of it and she asked.
12:40:12 15
And I don't -- she was just, "Wow. You know, what
16 are you going to do?"
17
And I was like, "I'm going to have it. I'm
18 not going to ... " -- she wasn't trying to convince me
19 one way or the other of anything.
12:40:27 20
Q. What position did Melissa Brown hold at that
21 time?
22
A. She was just a close friend of mine who held
23
an equal position in the org. I don't remember what
24
it was but she was equal at that point.
12:40:39 25
And then I spoke again with Gabriella that
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Page 119
1 day.
2
Q. At her off ice?
3
A. Yeah. No, actually I spoke with Jesse again
4 on the phone the next day and at that point I could
12:40:57 5
tell that Chris had been talking to him more. He
6 had said Chris had been talking to him and I could
7 see his change of tone because then he was
a saying that he didn ' t want to leave and he was
9 worried about not being able to raise a baby and
12:41:24 10
blah, blah, blah. He was like back under the paw of
11 Chris basically. And so then he's like, "Maybe the
12
right thing is to have an .abortion." And he and
13 then the thought was put out there by either him or
14 Gabriella, I can't remember who, that what would
12:41:46 15
happen if he didn't go with me.
16
Q. And tell me what that thought was. What was
17 the that went along with that thought.?
18
A. Of, you know, he didn't want to leave the
19
Sea Org so what was going to happen would be, you
12:42:07 20
know -- or the thought of possibly having to leave
:ir: i

-
12:42:31
:r,
21
22
23
24
25
the Sea Org with the bill and no - -
MR. BRODY: Why don't we take a short break
here.
THE WITNESS: I don't want to stop and then
come back to it. It doesn't help me:
9d3e434e-b102-44 78-ae28-d1 e944090d2e
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1
He was saying what if he stayed because he
2 didn't want to leave. So then it became not only
3 would I have to go but there was the threat of
4 having to go by myself. And here I am at 17 going
12:42:53 5
to go out.with no education, no high school diploma
6 other than an equivalency certificate, no real
7 schooling. I'm going to go out and have a baby by
B myself? I couldn't do that anymore. So then it
9 became like I didn't have a choice anymore.
12:43:24 10
Q. So if I understand, at some point in this
11 second day that we've been talking about and you're
12 talking to Jesse and he s a ~ d , "You know, I don't
13 want to leave," it somehow had been imparted to him,
14 I take it, that if you had a baby he would have.to
12:43:39 15
leave the Sea Org?
16
A. Yes.
17
Q. Do you recall what it was that he said he
18 had learned that was the then policy; that if you
19 kept the baby he'd have to leave the Sea Org?
12:43:50 20
A. The day before when we were talking with
21
Gabriella and Chris, that was the thing that was
22
communicated is that we would have to leave. It
23
would not be that we would go to a Class V org.
24
Q. I see. Do you remember if it was either
12:44:04 25
Gabriella or Chris who said that to you?
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1'..;
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1
A. I know Gabriella had said that to me before
2 we called and we're on the phone with them, so I'm
3 sure Chris probably said the same to him. I don't
4 know.
5
Q. Did Gabriella tell you when that policy had
6 become effective?
7
A. No. She said they're not -- it's not going
a to happen that way anymore. That's all she said.
9
Q. Not going to happen that way anymore
10
referring to your being transferred to a Class V
11 org?
12
A. Right.
13
Q. So that was one of the things that you and
14 Jesse talked about the evening after your meetings
15
with Chris and Gabriella and you had decided to keep
16 the baby, and then in the next day's conversation,
17 if I'm understanding, Jesse says to you I don't want
18 to leave and you and he begin having discussion
19 along the lines that you have just described; is
20
that right?
21
A. Yes.
22
Q. Okay. And -- so after -- you say then there
23
was some discussion either with Gabriella or with
24 Jesse about the possibility of your having the baby
25
yourself. In other words, you would leave and you
\.If'

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1 would then be solely responsible for the baby,
2 correct?
3
A. Right.
4
Q. So after you had those discussions, what
12:45:46 5
discussions did you have next with Jesse or anyone
6 else within the org about keeping the baby or not?
7
A. Then I spoke to Gabriella again and she
8 started going on about -- back on the subject of it
9 not being formed enough to matter and how -- you
12:46:19 10
know, she would tell me, you know, "Well, I did it
11 because I knew that it was the g r e a t ~ s t good
12 and ... " - - yeah, that ' s what I remember. And then
13 finally I said -- I spoke to Jesse again and I
14 said -- at one point he told me -- what did he say?
12:46:54 15
He said, "Let's just do the abortion so that ... " --
16 and then, you know, "We both have always wanted to
17 be in the Sea Org," and blah, blah, blah, and
18 started pushing that whole thing.
19
Q. When you say "blah, blah, blah," do you
12:47:08 20
remember anything else that Jesse said that would be
21 included in the blah-blah?
:fl"''
22
A. The whole thing of the greatest good for the
.
23
greatest number of dynamics and more jargon about
24
that and -- and then he started pushing the thing of
i 12:47:29
25
it's not really -- there's no Thetan there yet and
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1
it's not you know, it's just tissue-type thing
2 because I'm guessing that he's being told that, too.
3 And -- and then Gabriella talked -- we talked again
4 and I finally after two days of this said, okay, and
12:47:55 5
then we said
6
Q. You said okay. You agreed to have an
7 abortion?
8
9 question. She was coerced into having an abortion.
12:48:07 10
You say agreed. I didn't open it.
11 BY MR. BRODY:
12
Q. You said you would have an abortion?
13
A. I said I would have an abortion because of
14 everything that had happened. And I even when I was
12:48:25 15
there still did not want to do it, but I did it
16 because of the -- everything that was going on.
17
Q. I take it at the time you and Jesse were
18 very much in love?
19
A. Sorry.
12:48:47 20
Q. I'm sorry.
jJ"'
21
A. Yes.
i"' .
. 1 .. 1
"il'l 22
Q. And you didn't want to lose Jesse?
"
,;':'1
23
A. Yeah.
" " ~
it
1
24
Q. And he's the reason.you said you would have
It,.,
t
12:49:10
25 an abortion?
' ~
....
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Page i24
1 MR. VAN SICKLE: Come on. Object to the
2
. form of the question.
3 THE WITNESS: No, he's not the reason.
4 MR. VAN SICKLE: That is just really, really
12:49:18 5
an incredibly-stupid questiop. Very inappropriate.
6 BY MR. BRODY:
7
Q. When you when you decided to get pregnant
8
without telling Jesse, did you think that you might
9
be forcing a choice upon him without asking him?
12':49:33 10
11
question. Argumentative, compound.
12
THE WITNESS: I don't have an answer for
13
that question.
14
BY MR. BRODY:
12:49:46 15
Q. You didn't think about it one way or the
16
other?
. 17
A. No, I had always wanted to have kids .
18
Q. And as I understandit, you were told that
19
you could have the baby but that you would be forced
12:50:11 20
to leave the Sea Org at that point; is that right?
21
MR. VAN SICKLE: Object to the fqrm of the
22
question. Argumentative, misstates the testimony.
23
THE WITNESS: What was your question again?
1,l)
24
'
BY MR. BRODY:

.. 12:50:25
1'-. J
25
Q. You were told -- I mean, you understood, I

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1
should say, during these discussions that you could
2 have the baby and if you had the baby you would be
3 required to leave the Sea Org, right?
4
12:50:38 5
question.
6
THE WITNESS: I was being told that the
7 greatest number of dynamics -- the greatest gift for
8 the greatest number of dynamics was that I had an
9 abortion.
12:50:47 10
BY MR. BRODY:
11
Q. I understand. And in addition to people
12 telling you what you've just told me, you also
13 understood that you could have the baby but if you
14 had the baby you'd be I think the term is
12:50:57 15
off-loaded?
16
A. Yeah, the term is off-loaded. But in their
17 minds that was not even a thought of let's -- let's
10 just put her on a routing form to off-load her.
19 That never happened.
12:51:11 20
Q. Well, they told you that they thought the
21
greatest good for the greatest dynamic was for you
22
to have an abortion; is that right?
23
A. Yeah, and told me -- and had someone tell me
24
how they had just had an abortion a couple of months
12:51:22
25
earlier and, you know, it wasn't even a thought in
\."<Jr;
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1 their mind of possibly leaving and convincing me,
2 too, that it was the best thing.
3 Q. Did you ask if you could route out?
4 A. Yes. I said, "I'm going to have this kid."
12:51:33 5 Q.
And when you said you wanted to route out,
6 what were you told in response?
7 A. They -- it's not -- it wasn't like, "Okay,
8 let's ioute you out." It was, "Okay, well, let's
9 take a look at this." Let's -- that's what it was.
12:51:50 10 Coercion.
11 Q. When you say "coercion," was there something
12 more that was said than .what you've told me thus
13 far?
14 A. Is that not coercion?
12:51:59 15 Q.
I don't know. So they told you that the
16 greatest good for the greatest number of dynamics
17 would be accomplished if you aborted; is that right?
18 A. Yes, and
19 Q. And they told you that in their view what
12:52:12 20 you were carrying was not yet a Thetan; is that
21 right?
22 A.
There was no Thetan there.
23 Q.
What does that mean in Scientology
24 terminology; that there's no Thetan there?
25 A.
There's no spiritual being there.
:?;,;:
1
9d3e434eb102-44 78ae28-d1 e944090d2e
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1 There's -- that the baby at that point is just
2 tissue. That's what I was told.
3 Q. And they told you that you and Jesse both
4 had important responsibilities in the Sea Org; is
12:52:38 5
that right?
6
A. Yes.
7
Q. And that if you had the baby, you would have
8 to leave the Sea Org?
9
A. Yes.
12:52:44 10
Q. And that if you left the Sea Org you and
11 Jesse would be abandoning the important positions
12 that you and Jesse had; is that right?
13
A. Yes.
14
Q. Did anybody physically force you to go to a
12:52:56 15
clinic and have an abortion?
16
MR. VAN SICKLE: You're going to defend the
17 case on this? Good luck. Object to the form of the
18 question. You're arguing and you're demeaning the
19 witness right now.
12:53:10 20
MR. BRODY: Would you read the question back
21
to the witness, please. You may answer the
22
question, ma'am.
23
THE WITNESS: No one physically forced me to
24
have an abortion. I was so -- you have to realize I
ji,,. 12:53:21 25
grew up in Scientology, okay? I knew no other way
9d3e434e-b102-4478-ae28-d1 e944090d2e
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I
Page 128
1
of life other than Scientology. I had been
2
programmed a certain way. I joined the Sea
.3 Organization at 12 when most kids should .be living
4
with their parents and going to school. ,And here I
12:53:44 5
was at 17 thinking, okay, I'm going to have a kid
6
and I'm told, well, here's -- here's the dynamics.
7
You know, look at this. Look at how much this is
8
going to affect your dynamics if you have a kid and
9
blah, blah, blah, blah, blah -- everything I said
12:54:01 10
earlier and not just blah, blah, blah, blah, blah.
11
But so I'm basically being -- and because
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I'm so programmed to think that way there was no
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other option for me at that point. I'm now so
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convinced by these people that that's the only
12:54:21 15
option I have.
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BY MR. BRODY:
17
Q. That's what you concluded?
18
A. Yeah.
19
Q. Was there anything else that Gabriella said
12:54:43 20
to you that you would tell me you thought was
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coercion to get you to agree to an abortion in
22
addition to what you've told me so far?
I":,
23 A.
No.
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Q. And did Chris, whom you had hung up on in

ff:.fi 12:54:56 25
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1 would tell me in your mind constituted coercion to
2 get you to agree to have an abortion?
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A. No.
4
Q. During this period while you and Jesse are
5
making this decision, didn't he keep telling you
6 that he was concerned that the two of you couldn't
7 support a child with you guys being, what,. 17, 18
8 years old?
9
A. He brought that up once.
10
Q. And what did you say to him in response to
11 that concern?
12
A. I said we have many options. Together we
13 have many.options. My parents own and operate a
14 business in Albuquerque, New.Mexico. We could
15
easily move there. You would have a job. His
16 dad -- his step-dad worked at Survival Insurance.
17 He could easily go over there and get a job. I had
10 no -- I knew that if .I -- if -- yeah.
19
Q. But Jesse told you that he didn't want to
20
leave the Sea Org?
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A. And then, yes, after a bit he said that.
22
MR. BRODY: Why don
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break here.
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VIDEO OPERATOR: Going off the record. The
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A. Yes.
2
Q. And the three paragraphs that are in the
3 regular unitalicized Arial font, that's your
4
response to Smurf's posting?
04:52:17 5
A. Yes.
6
MR. BRODY: Let's go off the record for a
7 moment. I may be at an end.
8
THE WITNESS: Okay.
9
MR. BRODY: Let me check with my colleagues.
04:52:30 10
VIDEO OPERATOR: Going off the record. The
11 time is 4:52 p.m.
12 (Brief recess. )
13
MR. BRODY: So we're going back on the
14 record of the court reporter but not the
04:57:08 15
videographer since video is not needed for this
16 portion. I've advised Mr. Van Sickle that I have no
17 further questions. Mr. Van Sickle has advised me
18 that he has no redirect. So we are done with
19 today's deposition.
04:57:23 20
I will propose the following stipulation:
21
That the court reporter may be relieved of
22
her obligations under the Federal Rules of Civil
23
Procedure; that the original of the transcript will
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be sent to Mr. Van Sickle. Mr. Van Sickle will have

25
the responsibility of getting the original, or a
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1 copy thereof, to Ms. Dieckman for her review.
2 Ms. Dieckman will have 30 days from the date of
3 mailing from Mr. Van Sickle in which to review the
4 deposition transcript, make any changes, and to sign
5
under penalty of perjury. If she fails to complete
6 that process within that time, or any extended
7 to which we may stipulate, a certified copy of the
8 deposition may be used as if it's been signed under
9 penalty of perjury. Mr. Van Sickle will have the
10
responsibility of advising me of any changes or
11 corrections that Ms. Dieckman makes to the
12 deposition transcript and providing me with a copy
13 of the signature page showing the date of signature
14 and her signature. You will also have the
15
responsibility of maintaining the original and
16 filing it with the court in advance of trial or in
17 advance of any other proceeding in which the
18 deposition or portions thereof are needed?
19
MR. VAN SICKLE: Would you give me 30 days?
20
MR. BRODY: I'm sorry if I didn't.
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MR. VAN SICKLE: I wasn't clear.
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MR. BRODY: Yes, I think I did say 30 days.
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MR. VAN SICKLE: With 30 days that's so
24
stipulated.
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MR. BRODY: Thank you very much.
t;2! Network Deposition Services, Inc. networkdepo. corn 866-NET-DEPO
9d3e434e-b102-4478-ae28-d1e944090d2e
STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
SS:
I, WENDY S. SCHREIBER, do hereby certify:
That I am a duly qualified Certified Shorthand
Reporter, in and for the State of California, holder of
certificate number 3558, .which is in full force and
effect and that I am authorized to administer oaths and
affirmations;.
That the foregoing deposition testimony of the
herein named witness was taken before me at the time and
place herein set forth;
That prior to being examined, the witness named
in the foregoing deposition, was duly sworn or affirmed
by me, to testify the truth, the whole truth, and
nothing but the truth;
That the testimony of the witness and all
objections made at the time of the examination were
recorded stenographically by me, and were thereafter
transcribed under my direction and supervision;
T h ~ t the foregoing pages contain a full, t r u ~
and accurate record of the proceedings and testimony to
the best of my skill and ability;
That prior to the completion of the foregoing
deposition, review of the transcript was requested.
.1
2'55
I further certify that I am not a relative or
employee or attorney or counsel of any of the
nor am I a relative or employee of such attorney or
counsel, nor am I financially interested in the outcome
of this action.
IN WITNESS WHEREOF, I have subscribed my name
this 8th day of February
2010
WENDY S. SCHREIBER, CSR No. 3558
. 256
Network Deposition Services, Inc. net:Workdepo.com
,9
EXHIBIT 2
JJQ.1
Laura Ann DeCrescenzo v. lch of Scientology International, et al. Laura Ann Dieckman - Volume 1
r-
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
LAURA ANN DeCRESCENZO
Plaintiff,
versus
entity, RELIGIOUS TECHNOLOGY
CENTER, previously sued herein
as DOE No. 1, a California
Corporation, and DOES 2-20
Defendants.
No. BC411018
DEPOSITION OF: LAURA ANN DIECKMAN
TAKEN ON: May 1, 2012
VOLUME 1: Pages 1 through 209, inclusive
31843 ALTHEA L. MILLER
CSR No. 3353, RPR, CCRR
Miller & Company Reporters (310) 322-7700 ~ (415) 956-6405 (800) 487-6278
www.millerreporters.com
EXHIBIT 2
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Laura Ann DeCrescenzo v. Church of Scientology International, et al. Laura Ann Dieckman - Volume 1
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my audio. It would have to be someone with a 09:00:42 1 Q Dieckman. Okay.
microphone. Okay. Sorry about that. 09:00:42 2 Good morning, Miss Dieckman.
MR. DEIXLER: I'll just tum this off. 09:00:44 3 A Good morning.
THE VIDEOGRAPHER: That will be helpful. 09:00:44 4 Q You understand you're here today to give
Thank you. 09:00:47 5 your testimony under oath under the penalty of
If I could have counsel please identify 09:00:48 6 perjury?
themselves for the record. 09:00:49 7 A Yes.
MR. DEIXLER: Bert Deixler, Kendall Brill & 09:00:50 8 Q Okay. Tell me, if you will, how you
Klieger, on behalf of the defendant -- 09:00:53 9 prepared for your deposition.
MR. DAVIDSON: Cliff -- 09:00:55 10 MR. BLUMBERG: And you may exclude anything
MR. DEIXLER: - CS!. 09:00:57 11 that your attorneys were going over with you.
MR. DAVIDSON: Excuse me. Cliff Davidson, 09:01:02 12 THE WITNESS: Okay.
Kendall Brill & Klieger, on behalf of CS!. 09:01:02 13 I came here and met with my attorneys and
MR. BLUMBERG: John Blumberg and 09:01:06 14 reviewed the documents that were provided.
Sindee Smolowitz, Blumberg Law Corporation, 09:01:09 15 BY MR. DEIXLER:
representing the plaintiff, and if we could also 09:01:10 16 Q Okay. About how much time did you spend
have the identification of everyone else who is in 09:01:12 17 with your attorneys?
the room before we start, please. 09:01:14 18 MR. BLUMBERG: I'm going to object to
MR. MANGELS: I was going to identify 09:01:15 19 questions about how much time she spent with her
myself too. 09:01:18 20 attorneys or anything else .that she did with her
Robert Mangels of Jeff er Mangels Butler & 09:01:20 21 attorneys as a part of the attorney-client
Mitchell for Religious Technology Center. 09:01:22 22 privilege.
MR. LIEBERMAN: Eric Lieberman, 09:01:22 23 BY MR. DEIXLER:
Rabinowitz, Boudin, Standard, Krinsky & Lieberman, 09:01:33 24
Q You testified that you reviewed some
from New York on behalf of CS!. 09:01:34 25 documents with your attorneys. Did I understand
Page 6 Page 8
MR. CARTWRIGHT: Allan Cartwright, client 09:01:35 I correctly that portion of your testimony?
representative for CSL 09:01:38 2 A Yes.
MR. PEDERSEN: Philippe Pedersen from 09:01:38 3
Q
And did the review of any of those
Church of Scientology International. 09:01:40 4 documents bring to mind or refresh your memory about
THE VIDEOGR.APHER: Thank you very much. 09:01:43 5 any topics?
This is the beginning of Master No. I. You 09:01:49 6 A Of course, you know, there were checksheets
may administer the oath. 09:01:51 7 and other courses that I did that it reminded me of
09:01:57 8 my - my training in Scientology.
LAUR.A ANN DIECKMAN, 09:02:00 9
Q
Okay. Anything else that you looked at
having declared under penalty 09:02:02 10 that refreshed your memory aside from the
of perjury to tell the truth, was 09:02:05 11 checksheets and the enumeration of courses?
examined and testified as follows: 09:02:09 12 A No.
09:02:10 13
Q Okay. Other than meeting with your
EXAMINATION 09:02:14 14 attorneys and reviewing the documents that you've
BY MR. DEIXLER: 09:02: 16 15 identified, did you do anything else to prepare for
Q
Good morning. 09:02:18 16 your testimony?
A Good morning. 09:02:19 17 A No.
Q
I should begin by asking you how you would 09:02:20 18
Q Okay. Where do you currently reside?
like to be addressed. 09:02:27 19 A In Albuquerque, New Mexico.
A Laura. 09:02:30 20
Q
And are you today married?
Q
It's a formal proceeding; so I'd like you 09:02:32 21 A No.
to choose which last name I should address you. 09:02:34 22 Q And do you live with someone?
A Dieckman. 09:02:36 23 A Yes.
Q
Say it again? 09:02:36 24
Q And who is that?
A Dieckman. 09:02:38 25 A Daniel Turner.
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A It- 14:18:29 I A That's correct.
Q What was the last date? 14:18:29 2 Q So we have the best of your memory about
A It only went up through when I was the 14:18:31 3 the emails right now; correct?
CIC Dir which was 1995, I think. 1994, '95. 14:18:33 4 A Yes.
Q Okay. What else in the way of documents 14:18:34 5 Q And you remember that there were more than
did you find in that box? 14:18:35 6 one; true?
A I believe I gave everything -- 14:18:36 7 A I'm pretty sure.
MR. BLUMBERG: No. He's asking you what 14:18:37 8 Q Okay. Can you -- can you be any more
you found. 14:18:39 9 certain about the number of emails?
THE WITNESS: Yeah. I found the passport, 14:18:42 10 A I think that it went back and forth two,
the -- the CSW, and then other pictures from when I 14:18:46 II maybe three times.
was there. 14:18:46 12 Q So you were responding to -- to whatever it
I think that's it. 14:18:49 13 is he was saying?
BY MR. DEIXLER: 14:18:50 14 A Yes.
Q And you turned them over to your lawyer? 14:18:50 15 Q Do you recall anything that you said in
A Yes. 14:18:52 16 response?
Q Okay. Didn't hold anything back? Didn't 14:18:55 17 A No.
withhold anything? 14:18:56 18 Q Okay. So you don't remember the topics
A No. 14:18:59 19 that were discussed either by Mr. Danilovich or
Q Okay. So we were on the topic of the 14:19:04 20 yourself in the two or three email exchanges that
conversations, communications, I guess, more 14:19:07 21 went between you; is that fair?
broadly, that you had with any Sea Org member after 14:19:09 22 A That's correct.
the birth of Kylie through mid-June, 2008, when you 14:19:10 23 Q Okay. And you don't know where the emails
first came upon the former Scientologist website. 14:19:12 24 are; true?
Do you have that time period in mind? 14:19:13 25 A Correct.
Page 146 Page 148
A Yes. 14:19:13 I Q And you have no way.of refreshing your
Q Okay. So you've told me about the Rebecca 14:19:15 2 memory about their substance because you don't have
emails, and now we're up to Mr. Danilovich's emails 14:19:17 3 anything to do that; correct?
although you weren't exactly sure what time period 14:19:19 4 A Yes.
they fell into. 14:19:20 5 Q Okay. So what other Sea Org member can you
Do I that understand that correctly? 14:19:22 6 recall having had any conversations with during this
A Yes. 14:19:24 7 time period after the birth of your child and before
Q Okay. Mr. Danilovich sent you more than 14:19:28 8 mid-June, 2008, when you first came upon that -- the
one email in -- in that -- in the rough time period 14:19:34 9 website?
either shortly before or after the birth of your 14:19:34 10 A And so now we're getting into 2007, where I
child; is that correct? 14:19:38 II had numerous calls from a lot of people on buying
A Yes. 14:19:45 12 the Basics.
Q Okay. Do you recall the substance of the 14:19:47 13 Q Okay. Sales calls?
emails? 14:19:48 14 A Yes.
A No. 14:19:49 15 Q Okay. People from the church were calling
Q Anything particular about them stand out? 14:19:53 16 you to try to encourage you to get the -- I think
A It'd be assumptions. 14:19:57 17 you called them the updated version of the basic
Q You have no memory at all? 14:20:01 18 Scientology texts; correct?
A No. 14:20:05 19 A Correct.
Q And no way to refresh your memory because 14:20:06 20 Q And did you ever buy any of them?
you don't know where those emails are; correct? 14:20:08 21 A No.
A Correct. 14:20:08 22 Q Okay. And do you recall the identity of
Q And you don't have any notes, audiotapes, 14:20:13 23 the people who called you? Or do you have kind of a
or videotapes or the like to try to refresh your 14:20:16 24 blended memory that you --
memory; correct? 14:20:17 25 A I can list-
Page 1 7 Page 149
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Q - had a spate of calls? 14:22:38 I Q Had a pleasant conversation?
A I could list a number of them. 14:22:40 2 A Yes.
Q
Okay. 14:22:40 3 Q Okay. And how long did you spend with
A I wouldn't say it was necessarily all. 14:22:42 4 Sarah?
Q
Okay. Why don't you give us your best shot 14:22:43 5 A She was at my office for probably two to
right here. 14:22:46 6 three hours.
A Melissa Brown, Mandy Kember, Laurie Modras, 14:22:47 7 Q Okay. Did you talk about things besides
Chris Swanson, Gavino ldda. 14:22:49 8 buying the Basics, like updating each other on your
Q Gavino ldda is one name? 14:22:52 9 life and her life and things that were in common to
A Yes. 14:22:55 10 the two of you?
Q Okay. 14:22:56 II A Yeah.
A I believe someone else from OSA - Gavino 14:22:57 12 Q Okay. And you told her about things in
and someone else. KO maybe. 14:23:01 13 your life that were going well; correct?
Sarah Wilbur was at my house. 14:23:05 14 A Well, yeah. I had my daughter there with
Quinn Taufer, Kenny Davies. 14:23:08 15 us; so -
Those are the ones that come lo - off the 14:23:09 16 Q Right And you talked about your partner?
top of my head. 14:23:12 17 A Yeah. I don't know.
Q Okay. Does -- I guess I should start with 14:23:13 18 Q No? Maybe not?
Sarah since she was at your house. 14:23:13 19 A I don't know.
How did it come about that Sarah was at 14:23:14 20 Q Talk about your job?
your house? This was in 20071 14:23:16 21 A I wasn't working then.
A Correct. 14:23:17 22 Q Okay. Were you still -- still minding
Q
Okay. How did Sarah come to be at your 14:23:20 23 your -- your daughter.
house? 14:23:22 24 So you were able to put it at early in
A She was in Albuquerque doing fundraising 14:23:24 25 2007?
Page 150 Page 152
for the new building that they were buying - 14:23:30 1 A Versus what?
Q Uh-huh. 14:23:31 2 Q Later in 2007 when you were working from
A -- and came to my house to try and sell me 14:23:33 3 time to time, if I understood your testimony
the Basics. 14:23:36 4 correctly.
Q Did she show up, or did she call in 14:23:39 5 A I worked from time to time all throughout
advance? 14:23:41 6 2007.
A I don't recall. 14:23:44 7 Q Okay. So even though you had your child
Q Okay. Did you have any preexisting 14:23:46 8 and Sarah was there, you recall you didn't discuss
relationship with Sarah? Did you know her when you 14:23:51 9 with her anything about your job, that is, selling
were in the Sea Org? 14:23:55 10 jewelry from time to time?
A Yes. We were friends. 14:23:56 II A I don't recall.
Q Okay. And had you in any way kept in touch 14:23:57 12 Q Okay. Anything else you recall about your
with her after you left the Sea Org? 14:23:59 13 conversation with Sarah in your home --
A No. 14:24:02 14 A She-
Q Okay. So she either just appeared on your 14:24:03 15 Q -- fn early, 2007?
doorstep or called you in advance to talk to you 14:24:05 16 A She was having me call other Scientologists
about buying the new Basics. Is that fair? 14:24:10 17 to see ifl could borrow the money to buy the
A Yes. 14:24:15 18 Basics.
Q And whichever it was -- whether in -- 14:24:18 19 Q Okay. You told her in substance, "Gee, I
invited or uninvited at your doorstep, you let her 14:24:2I 20 can't really afford these now." Is that one of the
in the house? 14:24:25 21 messages you were communicating to her?
A Correct. 14:24:27 22 A Yes. I said I do not have the money right
Q Okay. And you sat down and chatted with 14:24:29 23 now.
her? 14:24:29 24 Q Okay. What you didn't say to her was "I'm
A Yes. 14:24:33 25 not going to buy these ever under any circumstance"
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or words to that effect; correct? 14:27:05 I as far as you knew?
A Correct. 14:27:08 2 A Yeah.
Q Okay. And so she said "Well, let's see if 14:27:08 3 Q Okay. And you spoke to him in 2004?
we can get you together with some other 14:27:12 4 A Yes.
Scientologists who might lend you the money so you 14:27:12 5 Q
And you reported to him on your life, and
can buy these things"; correct? 14:27:15 6 he reported to you on his life; correct?
A Yes. 14:27:19 7 A Yes.
Q And did you take up her suggestion and call 14:27:19 8 Q Okay. And Mike, when you spoke to him -- I
some Scientologists? 14:27:25 9 think I understood you to say there were other
A Yes. 14:27:27 . 10 people present?
Q Okay. Was she present when you made the 14:27:30 II A lfhe was at the-whatever- that I was
calls? 14:27:33 12 talking about, the gathering of people that I was
A Yes. 14:27:36 13 thinking of, yes, there were other people present.
Q And about how many people did you call to 14:27:40 14 Q
What -- what was the gathering, and who was
ask for money to buy these new improved Basics in 14:27:41 15 present at this gathering?
2007? 14:27:45 16 A Stuart Huff; Garth Simington; Ashleigh now
A I know I spoke to one, two - I'd say three 14:27:52 17 Dowswe!! - she was married to Garth at the time;
or four. 14:27:56 18 Misha Korringa. I don't remember:... I don't know
Q Do you recall who you called? 14:28:05 19 what her last name is now,
A David Saunders, Mike Valiente, and I seem 14:28:12 20 And I'm pretty sure that Mike and Katie
to reca!! there being more, but that's who I 14:28:15 21 came over once during that time. But yes. It's
remember off the top of my head. 14:28:18 22 very vague.
Q Okay. And were these phone numbers that 14:28:19 23
Q
And that's Mike Valiente and Katie?
you had or that were supp!ied to you by - by Sarah? 14:28:23 24 A Valiente.
A By Sarah. 14:28:25 25 Q
Valiente.
Page 154 Page 156
Q
Okay. And she was there while you called? 14:28:26 l Okay. And this gathering that you were
A Yes. 14:28:28 2 speaking of or gatherings -- when, approximately,
Q
Okay. And were these people whom you had 14:28:31 3 did they occur?
known from your days at the Sea Org? 14:28:41 4 A 2005. Early 2005.
A Yes. 14:28:43 5
Q
Okay. And where did they occur?
Q
Okay. And you hadn't spoken to for a few 14:28:46 6 A In L.A.
years; correct? 14:28:47 7 Q
Okay. And were the folks whom you
A In some cases, yeah. 14:28:49 8 identified -- Stuart, Garth, Ashleigh,
Q
Okay. And the persons whom you called for 14:28:52 9 Misha Korringa -- in the Sea Org at the time?
loans, you had spoken to - who was the person you 14:28:57 10 A No.
had spoken to most recently among those whom you 14:28:57 11
Q
They had left the Sea Org?
called for loans? 14:28:59 12 A Yes.
A I think I had spoken to Mike Valiente - I 14:28:59 13 Q
Okay. And you were meeting with them --
don't remember. Not sure. I'm not sure if Mike was 14:29:02 14 had they -- any of them been declared?
there because there's a time period in 2004 when I 14:29:04 15 A Not- no.
was with some other - ex-husband - I'm not sure if 14:29:05 16 Q
Okay. And what was your reason for being
Mike was there or not. He may have been - 14:29:12 17 in Los Angeles and attending this gathering with
David Saunders I had spoken to in 2004: He 14:29:15 18 these folks?
was already out, had been for a while. 14:29:16 19 A I was working for Second Chance,
Q
Okay. Had he -- had he been declared? 14:29:18 20 Rick Pendery, and I was meeting with them on the
A No. Not that I'm aware of. 14:29:22 21 weekend at a barbecue al Garth's house.
Q
Okay. He had routed out? 14:29:27 22
Q
Okay. So these were people that you had
A Yes. 14:29:29 23 been in the Sea Org with and remained friendly with;
Q
Okay. He had been in the Sea Org with you; 14:29:33 24 correct?
he had routed out; and he is going about his life, 14:29:33 25 A Yes.
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Laura Ann DeCrescenzo v. C'ch of Scientology International, ct al.
LauraAnn Dieckman - Volume 1
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I I talked about that.
2 Q Okay. And this was in 2007 or 2006?
3 A '7.
4 Q Okay. And that was in - was it on a video
5 screen presented from Los Angeles or something local
6 in Albuquerque presented by somebody local?
7 A It was a video satellite broadcast from
8 Los Angeles.
9 Q And who was the presenter?
10 A David Miscavige.
11 Q And it was at the Shrine Auditorium, a
12 large gathering of people as he presented?
13 A I don't know. I wasn't there. I was in
14 Albuquerque.
15 Q Yes, but you were viewing it on a screen?
16 A Yeah.
17 Q And could you tell whether it was a large
18 venue?
19 A Yeah.
20 Q Could you tell whether there were other
21 people besides Mr. Miscavige present in the large
22 venue, or did you have the impression that it was
23 Mr. Miscavige in, say, the Shrine Auditorium seating
24 about 3,000 people, and he was there by himself?
25 A I knew that there were people at the event.
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I and Melissa all started going into whether or not I
2 had doubts about Scientology. They were-asking me
3 if I had doubts about Scientology, al which point I
4 said no, and I know I got quite - I got quite upset
S when I was talking to Mandy and Chris and Laurie.
6 Q Okay. So let me just see ifl can-- did
7 Laurie, Melissa, and Mandy each independently ask
8 you about whether you had doubts about Scientology?
9 A Mandy, Laurie, and Melissa I recall
I 0 specifically all asking me that.
11 Q Okay. In the course of a - what I'll call
12 a sales call?
14:36:36 13 A Yes.
14:36:37 14 Q Okay. About how long did these sales calls
14:36:39 IS last with Mandy and Melissa and Laurie?
14:36:51 16 A I don't recall. I definitely- I don't
14:36:56 17 recall. I couldn't answer that. It was a long
+-.;.14,;,,;:.;.36;;,;:.;.58;;__..;18 time. Over days.
14:36:59 19 Q Okay. So the phone calls that you had with
14:37:01 20 each of them -- were they hour-long phone calls,
14:37:04 21 two-hour long phone calls with each? Or are you
14:37:08 22 being - the call had short conversations with --
14:37:09 23 with them over a few-day period?
14:37:14 24 A I had long conversations with Melissa for
14:37:23 25 sure; and I couldn't tell you how long the other
Page 162 Page 164
I Q Okay. All right. Anything else that you 14:37:26 I ones were, to be- and be accurate on it.
2 can remember about the conven;ations with 14:37:29 2 Q Okay. And by "a long conversation," how -
3 Sarah Wilbur? 14:37:32 3 how long?
4 A No. 14:37:32 4 A Sorry. 1- I honestly did not -1 didn't
S Q Okay. Anything unpleasant about it? Did 14:37:36 5 keep track of it.
6 you throw her out on the step or something after 14:37:37 6 Q I - what's your best estimate?
7 this discussion? 14:37:38 7 A 1-1 don't know.
8 A No. 14:37:44 8 Q We've been -- since lunch, you've been
9 Q Okay. You --you parted friends; correct? 14:37:46 9 testifying about an hour. Do you recall ifthe
10 A Yes. 14:37:48 10 conversations with Melissa were as long as this one
11 Q Okay. How about any of the other people 14:37:52 11 hour or not as long?
12 whom you've identified -- Melissa, Mandy, Laura, 14:37:55 12 A I do not recall.
13 Chris, Gavino, Quinn, or Kenny? 14:37:56 13 Q Okay. You have no way of fixing the amount
14 Did any of those people communicate with 14:37:59 14 of time you spent on that call?
IS you in person, face to face? 14:38:01 15 A No. Other than lfelt like it was a long
16 A Unh-unh. No. 14:38:04 16 con- - long time.
17 Q Okay. They called you on the phone? 14:38:05 17 Q Okay. And were the conversations that you
18 A Yes. 14:38:07 18 had with Mandy and Laurie shorter or longer than the
19 Q On -- on that cell phone? 14:38:11 19 conversations with Melissa or the same length?
20 A On my cell phone. 14:38:14 20 A A bit shorter.
_.. _____ ...
21 Q Okay. And, in substance, each of them had 14:38:15 21 Q Okay. And other than "Hey, you really need
22 the same presentation to you? "Hey, you should buy 14:38:18 22 to buy the new, improved Basics," anything else that
23 this. This will be really good for you," or words 14:38:23 23 stands out in your mind about the conversations
24 to that effect? 14:38:25 24 with -- conversation with Melissa?
25 A No. Mandy Kember and, I believe, Laurie - 14:38:48 25 A Just the- just her asking me about if I
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I had doubts about Scientology, which I said no,
2 because I didn't at that point, and the - no.
3 Q Okay. So you told me everything that you
4 recall about this conversation you had with Melissa?
5 A Yeah.
6 Q Okay. And there's no way you can refresh
7
8
9
10
your memory about that conversation because you
don't make notes and you don't have any tapes, audio
or video to assist. Is that true?
A That's correct.
11 Q And anything -- anything at all about the
12 conversation with Melissa that you can remember?
13 For example, did you tell her "I can't afford to buy
14 the books -- I won't buy the books"? Anything like
15 that?
16 A I told her I don't have the money to buy
17 the books.
18 Q Okay. Did she ever call you back after
19 that?
20 A I believe she tried to call me a few times,
21 and then I stopped answering after a while.
22 Q Okay. And how did you know she tried to
23 call you?
24 A Because I'd see the number on my phone.
25 Q Okay. And how long after this initial
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A Within a week or two.
Q Okay.
A And it's - yeah. That's it.
Q Okay. So in 2007, in the first part of the
year, you also then spoke to -- to Laurie and Mandy
on the telephone; correct?
A Yeah.
Q And was the substance of the calls with
them the same, but the duration was shorter, as was
your phone call with Melissa?
A Yes.
14 Q Okay. You have sort of a blended memory of
15 those three calls?
16 A Yeah.
17 Q And all three people asked you whether you
18 had doubts about Scientology; correct?
19 A Correct.
20 Q And you reported to them truthfully that
21 you did not; correct? Is that true?
22 A Yeah.
23 Q Okay.
24 MR. BLUMBERG: Let's take a break, please.
25 MR. DEIXLER: Sure.
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1 THE VIDEOGRAPHER: We're going off the
2 record. The time is approximately 2:40.
3 We're off the record.
4 (A brief recess was taken.)
5 THE VIDEOGRAPHER: We are back on the
6 record. The time is approximately 2:52.
7 BY MR. DEIXLER:
8 Q We were on the topic of these
9 communications that you had by telephone with
10. Sea Org members. You told us about Mandy, Melissa,
11 and Laurie.
12 ls there anything else that you recall
13 about those phone conversations that you haven't
14 testified to?
15 A The only other thing that I reca!! was
16 Mandy doing - I - my memory is too vague to tell
17 you more than that. I do know that I got upset
18 during the phone call with Mandy.
19 I don't remember exactly all the details of
20 what she was saying, though.
21 Q Do you remember what upset you about the
22 conversation with Mandy?
23 A No.
24 Q Okay. Youjustrememberthatsomething
25 that she said or something you thought caused you to
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Page 168
be upset; right?
A Yes.
Q Okay. And by "upset," you meant what?
A I was crying on the phone.
Q Okay. And about how long were you crying
on the phone? The whole call? Half the call? Just
a small bit of the call?
A Few minutes.
Q Few minutes.
And then after you hung up, you were okay?
A That period was quite upsetting to me.
Q The period of people calling you in 2007
and asking you to buy the new, improved Basics?
14 A I wouldn't classify it as that- more than
15 the phone calls themselves.
16 Q The phone calls themselves were upsetting
17 to you?
18 A Yes.
19 Q And they were upsetting to you why?
20 A Because - how do I explain it? I don't
21 know how to explain it other than it was - I'm at a
22 loss for words here. I don't know how to - I don't
23 know how to explain it other than the content of her
24 asking me ifl was in doubt about Scientology, and
25 at that point that was offensive to me.
Page 16" Page 169
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I And at that point it was - there's kind of
2 two factors. Some of it was the content of what was
3 being gone over and some of it was - these were
4 people that were close to me when I was there, that
5 talking to them, like, I was there from - I grew up
6 there; so there were certain people that I was
7 closer to than others, obviously, and not - not -
8 not being able to talk to them regularly or - it
9 was stirring up old emotions and things that had
I 0 happened.
11 Q You missed the camaraderie with -- with
12 these people you had been close to for a long period
13 oftime. Is that true?
14 A That's not how I would phrase it.
15 Q Well, these people -- many of them were
16 your good friends during the time you were in
17 Sea Org; correct?
18 A Melissa was, yes.
19 Q Okay. And you experienced good things and
20 bad things, ups and downs, as we described them
21 before together; correct?
22 A Yes.
23 Q And now in your new life in Albuquerque,
24 you didn't have that same sense of camaraderie. It
25 was you and Daniel and your baby; correct?
Page 170
I A Correct.
2 Q And so you missed that aspect of -- of
3 life?
4 A No.
5 Q You didn't miss that aspect of being with
6 Melissa and your other friends?
7 A I would not phrase it as I missed the
8 camaraderie. I would phrase it as I missed that
9 person, and the - the conversations were stirring
10 up things that I tend to shelf.
II Q Uh-huh.
12 A That is what I would say.
13 Q Okay. And the persons you missed included
14 Melissa and who else?
15 A That's - what do you mean? Like -
16 that -you're saying -what is your question
17 again?
18 Q My question is besides Melissa, whom you
19 testified that you were close to and you missed,
20 were there other people who had called you whom you
21 also missed?
22 A Laurie.
23 The others were more the stirring-up aspect
24 that I was talking about.
25 Q Okay. And "stirring up" means that things
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I that you experienced or witnessed came back to
2 your -- to your memory?
3 A That I experienced, yes.
4 Q Okay. And did you discuss any of those
5 things with any of the people who -- with whom you
6 were speaking?
7 A Did I discuss what with them?
8 Q Any of the things that you -- came back to
9 your mind that you had experienced. Any -- any of
10 those you mentioned to them? "Hey, Melissa,
11 remember the time that"?
12 A Not that I recall.
13 Q Okay. You didn't discuss any of that with
14 any of those people; true?
15 MR. BLUMBERG: I'll object to the question
16 as vague and ambiguous.
17 THE WITNESS: It's hard for me to answer.
18 I don't -- there's nothing like the example that you
19 just gave me.
20 BY MR. DEIXLER:
21 Q Okay. You said that the phone calls, in
22 addition to reminding you that you missed certain
23 people, stirred up things which you had experienced.
24 Did I understand that correctly?
25 A Yes.
Page 172
I Q Okay. And what I'm trying to divine here
2 is whether, when you said that they stirred up
3 things that you had experienced -- whether you said
4 to any of the people who were on the phone with you
5 anything about what had been stirred up.
6 A And I - my answer is I don't recall.
7 Q Okay. For example, you don't remember
8 saying to Quinn or Kenny, "Hey, remember the time
9 that" or anything like that? Those -- anything
10 along those lines; correct?
11 A Correct.
12 Q Okay. So was there anything about your
13 conversation with Quinn, Kenny, Gavino, or Chris
14 that was different from the Melissa, Mandy, and
15 Laurie conversations?
16 A I don't remember.
17 Q Okay. You remember, in substance, they
18 were sales calls?
19 A Yeah.
20 Q Okay. And they were single calls?
21 A No. Gavino I spoke to several times.
22 Q Okay. And other than saying, "Hey, do you
23 want to buy these -- these works of scriptures?" is
24 there anything else that you can recall discussing
25 with Gavino?
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I Q Okay.
2 A And after, I think.
3 Q Andso--
4 A I'm sorry. I don't - because she had been
5 around that whole time period, and there were times
6 when I was - yeah. She has been around.
7 Q Had you worked with her too?
8 A (No audible response.)
9 Q Okay. So you told her that you were
I 0 bothered by the number of phone calls that you had
11 received, these sales calls.
12 Anything else that you remember telling her
13 that were -- that bothered you or upset you --
14 A No.
15 Q -- as a result of these calls?
16 Okay. Other than Felicia, who else did you
17 tell that you were bothered or upset by these phone
18 calls?
19 A Daniel.
20 Q Okay. And about how many times did you
21 discuss the topic with Daniel?
22 A I don't know. I couldn't answer that
23 question. I have no idea.
24 Q More than once?
25 A Don't remember.
Page 178
I Q Okay. Do you remember it being a very
2 emotional conversation with him?
3 A No.
4 Q Okay. Tell me, as best you can recall,
5 what you said to Daniel and he to you relating to
6 your phone calls with these eight people.
7 A I believe he saw my phone ringing, asked
8 who it was.
9 I - I feel like I'm speculating on
10 conversations that happened three years ago. I have
11 no idea.
12 Q Okay. You can't remember a single thing
13 that you said to Daniel or he to you on the occasion
14 of your having received these phone calls; correct?
15 A It would be speculation because I don't
16 remember the exact conversation.
17 Q Do you recall the substance of it?
18 A It was another call.
19 Q Okay. Anything else you remember other
20 than another call in substance?
21 A No.
22 Q Okay. You've told me everything that you
23 can remember about your conversations with
24 Felicia Huber on the topic of your having received
25 these calls?
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I A She was complaining about it as well.
2 Q Okay. What did she say?
3 A She said, like, I know - she said, "I .
4 don't answer my phone anymore at all. I'm getting
5 calls nonstop."
6 Q Okay. And so the experience you were
7 having with multiple calls was one that at least
8 Ms. Huber was having also; correct?
9 A Correct.
I 0 Q So you're sort of bonding on that subject
11 matter; correct?
12 A Yes.
13 Q Okay. Did she tell you that she was very
14 upset by it?
15 A No. She just said - she was
16 complaining - it was a complaining tone.
17 Q Okay. And you were reciprocating that
18 complaining tone?
19 A Yes.
20 Q Okay. And so next -- you've told me
21 everything you can recall about your conversation
22 with Daniel on the topic of your complaining about
23 phone calls?
24 A Yes.
25 Q Okay. And there's no way for you to
Page 180
I refresh your memory about what else you and Daniel
2 spoke of -- correct? --
3 A Correct.
4 Q - on that occasion?
5 Okay .. And you don't remember telling
6 Daniel, in effect, that you had memories being
7 stirred up or anything like that as a result of
8 these phone calls, did you?
9 A No.
I 0 Q Okay. So now we're in the first part of
11 2007. We're on the topic of Sea Org members with
12 whom you -- with whom you spoke or, I guess, more
13 broadly communicated, that is, by email or fax.
14 Did you have a telecopy machine -- have
15 access to fax machines?
16 A My mom does. I don't.
17 Q Okay. Do you remember receiving any faxes
18 from any member of the Sea Org?
19 A Not that I recall.
20 Q Okay. So the communications you had with
21 Sea Org members were either in person or on the
22 phone or by email; is that true?
23 A Yes.
24 Q Okay. So when is the next communication
25 that you remember having with a Sea Org member as we
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go through 2007? 15:12:51 I BY MR. DEIXLER:
A I know - I feel like I'm getting dates 15:12:52 2 Q Okay. So tell me what else there is about
mixed up because somehow my dates are not lining up 15:12:54 3 Kristina other than her selling you the simple
right because I know at some point I spoke to 15:12:57 4 lecture series that you acquired.
Kristina McDaniel and bought a single lecture 15:13:00 5 A I know that I bought that lecture series,
series. 15:13:02 6 and I bought the Clearing Congress; so I don't
Q You think this was in 2007 after these 15:13:05 7 remember if they were both at the same time or --
phone calls that we've been spending some time on? 15:13:08 8 Q Okay.
A I'm pretty sure. 15:13:10 9 A They were_ both with Kristina, though, as
Q Okay. And do you remember what the lecture 15:13:12 10 far as I remember.
series was? 15:13:14 II Q And the Clearing Congress relates to the
A I could look at home, but I don't remember. 15:13:16 12 teachings of Mr. Hubbard?
Q
Okay. You still have the book? 15:13:17 13 A Yes.
A The lecture packet. 15:13:18 14 Q Okay. And do you ever -- was that audio,
Q The lecture packet. Okay. 15:13:21 15 video, or which?
And that's Mr. Hubbard speaking? 15:13:26 16 A I think - I don't know. I - I don't know
A Yes. 15:13:29 17 if it's video or audio because I didn't listen to
Q On video or audio or both? 15:13:32 18 it.
A Audio. 15:13:33 19 Q Okay. You bought it and didn't listen?
Q Audio. 15:13:35 20 A Yeah.
And so -- and have you had the chance to 15:13:35 21 Q Okay. Did your dad listen to it?
listen to it? 15:13:38 22 A He may have.
A No. 15:13:39 23 Q Okay. Do you remember why you bought the
Q So from the time you bought it through 15:13:41 24 lecture series and the Clearing Congress at all?
today, you've never listened to it? 15:13:49 25 A Because I was called and asked to felt
Page 1 2 Page 184
A Correct. 1 I obligated to.
Q Ever opened the packet? 15:13:52 2 Q Okay. Felt obligated as a practicing
A I believe - yeah. I think my dad listened 15:13:58 3 Scientologist to buy it?
to it. 15:13:59 4 A Yes.
Q Okay. But you're sure you never did? 15:14:00 5 Q Okay. And was Ms. McDaniel a friend of
A Yeah. 15:14:09 6 yours when you were a member of the Sea Org?
Q Ever discuss it with your dad? 15:14:11 7 A Yes.
A No. 15:14:11 8 Q Okay. Have any special relationship with
Q Okay. 15:14:13 9 her? Very close relationship with her as you were
A And now - yeah. Sorry. I'm remembering 15:14:15 IO with Melissa?
other things. 15:14:16 II A No.
Q What is it you'd like to supplement your 15:14:16 12 Q Did you miss Miss McDaniel the way you
testimony with? 15:14:19 13 missed Melissa?
MR. BLUMBERG: Well, wait a minute. Did 15:14:21 14 A No.
you need-- 15:14:21 15 Q Okay. When speaking to Miss McDaniel, did
MR. DEIXLER: No. 15:14:24 16 that stir up any -- any things as speaking to
MR. BLUMBERG: Did you need to supplement 15:14:27 17 Melissa did?
your testimony, or are you just thinking of other 15:14:28 18 A No.
random things? 15:14:29 19 Q Okay. Anything else about your
THE WITNESS: No. 15:14:30 20 conversation with Kristina McDaniel which led to the
MR. BLUMBERG: Because he's not -- he's not 15:14:34 21 purchase of the Clearing Congress and the simple
entitled to know what you're thinking. 15:14:37 22 lecture series, other than what you've testified to
THE WITNESS: No. It's in regards to 15:14:41 23 that you can now recall?
Kristina, still. 15:14:42 24 A No.
Ill 15:14:43 25 Q Okay. Now, during this time period, we've
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15:24:55 I have? 15:27:05 I A -5th.
15:24:56 2 A I have an older sister and two younger 15:27:06 2 Q May 25th. You have one on the 27th of
15:25:00 3 sisters. 15:27:08 3 November--
15:25:01 4 Q And were any of the sisters in the church? 15:27:09 4 A And one on the 25th.
15:25:07 5 A Yes. 15:27:10 5 Q - and one on the 25th. Okay. See if I
15:25:07 6 Q Any of them still in the church? 15:27:12 6 can keep those dates in mind.
15:25:09 7 A No. 15:27:16 7 Other than this phone solicitation which
15:25:10 8 Q Okay. And were they part of your family 15:27:17 8 led to your buying an ethics book and prior to the
15:25:15 9 that you saw relatively regularly? 15:27:23 9 birth of your son, Tristan -- Tristan? --
15:25:18 10 A Yes. 15:27:27 10 A Yes.
15:25:18 II Q Okay. In this same time period that you 15:27:28 II Q -- with a T -- can you recall having had
15:25:22 12 and Daniel were living together in your house, he 15:27:30 12 any other contact with the Sea Org?
15:25:25 13 working and together raising a child; correct? 15:27:53 13 A I remember - this is now earlier.
15:25:28 14 A Yeah. 15:27:55 14 Q Okay.
15:25:29 15 Q Okay. So you've told me all of the 15:27:56 15 A llya called me when I was pregl\ant with
15:25:33 16 contacts you had with the Sea Org members in 2007. 15:27:59 16 Kylie to buy -- or to start paying for a lifetime
15:25:39 17 When is the next time you recall having had a 15:28:10 17 membership for Kylie in the IAS.
15:25:42 18 contact from a Sea Org member after 15:28:17 18 Q Okay. So Kylie was born in 2006. And sci
15:25:47 19 Kristina McDaniel? 15:28:23 19 this conversation would have taken place sometime in
.
15:25:53 20 A Someone -- and I do not remember who - 15:28:25 20 2006--
15:25:56 21 called me at some point in 2008 when I bought -- 15:28:26 21 A Yes.
15:26:01 22 because I bought the new "Introduction to 15:28:26 22 Q -- depending on how pregnant you were at
15:26:05 23 Scientology Ethics" book that came out. 15:28:30 23 the time; right?
15:26:11 24 Q Okay. 15:28:32 24 A Yes.
15:26:12 25 A And I don't remember who that was. 15:28:32 25 Q Okay. So I'm going to -- well, did you, in
Page 194 Page 196
15:26:14 1 Q Okay. Do you remember ifit was somebody 15:28:37 I fact, buy a lifetime membership for -- for Kylie?
15:26:16 2 whom you had known? 15:28:41 2 A No. I was going to put money towards it
15:26:18 3 A Yes. 15:28:45 3 and then didn't.
15:26:18 4 Q Okay. But you don't know who it is. Was 15:28:46 4 Q Okay. And any other contacts with the
15:26:20 5 it a man or a woman? 15:28:52 5 Sea Org that you can now recall through -- I guess
15:26:21 6 A I don't remember. Yeah. I don't remember. 15:28:59 6 really through May 25th, 2008, that you haven't
15:26:22 7 It would be speculation. 15:29:02 7 testified about?
15:26:24 8
Q
Okay. It was a telephone solicitation 15:29:15 8 A In end of 2006, I think, maybe even 2007 --
15:26:26 9 which you responded to by saying "Yes, I would like 15:29:27 9 I don't know - hmm - some point in 2006 or 2007,
15:26:28 10 to have the book"? 15:29:36 10 Jim and Karen Mangiamele bought my lifetime
15:26:29 II A Yeah. 15:29:43 II membership to the IAS, and I had a conversation with
15:26:30 12
Q
And why did you want an ethics book? 15:29:49 12 someone in the IAS at that time about where to mail
15:26:33 13 A Because I felt obligated to buy it. 15:29:52 13 it to.
15:26:35 14
Q Because you were a member of the religion? 15:29:52 14 Q Okay. And the IAS was one of the
15:26:38 15 A Yeah. 15:30:05 15 organizations within the Church of Scientology?
15:26:38 16
Q
Okay. And you weren't having any doubts 15:30:07 16 A Yes.
15:26:41 17 about the religion as of that time; correct? 15:30:08 17 Q Okay. Had you ever worked in the IAS?
15:26:44 18 A Correct. 15:30:10 18 A No.
15:26:45 19
Q Okay. During this -- and how far into 2008 15:30:10 19 Q Okay. Any other discussions,
15:26:47 20 are we now? January, February, March? 15:30:14 20 conversations, emails, that you can recall having
15:26:54 21 A I - I'm not sure. I don't - I don't 15:30:17 21 had with a Sea Org member during the time period
15:26:55 22 remember if I bought that book before or after 15:30:21 22 through the birth of your child on May 25th, 2008?
15:26:58 23 Tristan was born. I don't remember. 15:30:25 23 A Not that I recall.
15:27:01 24
Q Okay. So Tristan was born in May -- is 15:30:29 24 Q Okay. From the time you left the Sea Org
15:27:03 25 that right? -- May 28th? 15:30:35 25 in April of2004, until mid-June, 2008, when you
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EXHIBIT 3
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Laura Ann DeCrescenzo v . h of Scientology International, et al. Laura Ann Dieckman - Volume 2
LAURA ANN DeCRESCENZO
Plaintiff,
versus
Defendants.
No. BC411018
)
www.millerreporters.com EXHIBIT
3
Laura Ann DeCrescenzo v. clh of Scientology International, et al.
08:57:39
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Wednesday, May 2, 2012
8:57 A.M.
-oOo-
7 THE VIDEOGRAPHER: Good morning.
8 We're on the record. The time is
9 approximately 8:57. Today's date is May 2nd in the
JO year2012.
11 This is Volume No. 2 in the deposition of
12 Laura Ann Dieckman.
13 My name is Pierre Dupuy with Habeas Videas.
14 If I could have all present please identify
15 themselves for the record.
16 MR. DEIXLER: Counsel.
17 MR. BLUMBERG: John Blumberg and
18 Sindee Smolowitz representing plaintiff.
19 MR. MANGELS: Robert Mangels,
20 Jeffer Mangels Butler & Mitchell, for defendant,
21 Religious Technology Center.
22 MR. DEIXLER: Bert -- Bert Deixler for CS!.
23 MR. DAVIDSON: Cliff --
24 MR. LIEBERMAN: Eric Lieberrnan for CS!.
25 MR. DAVIDSON: Cliff Davidson for CS!.
Page 215
1 LAURA ANN DICKMAN,
2 having declared under penalty
3 of perjury to tell the truth, was
4 examined and testified further as follows:
5
6 EXAMINATION (Continued)
7 BY MR. DEIXLER:
8 Q Okay. You understand your testimony
9 continues to be under oath and subject to the
10 penalty of perjury?
11 A Yes.
12 Q You've had an evening to reflect upon your
13 testimony from yesterday.
14 Does anything, upon further reflection,
15 strike you as having been incorrect in your
16 testimony yesterday?
17 A No.
18 Q Did you bring with you any documents as
19 required by the court's order?
20 A I provided any documents I had to my
21 attorney.
22 MR. DEIXLER: Are you prepared to deliver
23 those documents?
24 MR. BLUMBERG: Absolutely.
25 MR. DEIXLER: And will you do so now?
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I MR. BLUMBERG: Of course.
2 MR. DEIXLER: Thank you.
3 MR. BLUMBERG: Let the record reflect that
4 I've handed a CD containing the documents in the
5 possession of the plaintiff that were responsive to
6 the request for production.
7 BY MR. DEIXLER:
8 Q I have a couple of cleanup matters that I
9 wanted to take care of as I looked over my notes
10 yesterday. I think this should proceed quickly.
11 You used the term a couple of times "CMO,"
12 and I forgot to ask you what that meant.
13 A Commodore's Messenger Organization.
14 Q And what is the Commodore's Messenger
15 Organization?
16 A It is an organization that was established
17 originally by L. Ron Hubbard on the ship when he
18 first started the Sea Org to service him and enforce
19 bis orders.
20 Q It -- it was part of the Sea Org?
21 A Yes.
22 Q And is there some sort of hierarchy within
23 the Sea Org of organizations, like the CMO is a
24 higher one, a lower one, a middle-rank one?
25 A Yes.
Page 217
1 Q And -- and which was it?
2 A It was a higher organization.
3 Q Okay. And you were in the CMO?
4 A Yes.
5 Q And for how long were you in the CMO?
6 A A hit over ten years.
7 Q Okay. And did you have to apply to become
8 amemberoftheCMO?
9 A No.
10 Q Okay. Were you - did you receive training
11 in order to become a member of the CMO?
12 A I received training while I was in the CMO.
13 Q Okay. And in technology, that would be
14 important for the discharge of your duties in the
15 CMO?
16 A Could you repeat that?
17 MR. DEIXLER: Sure. Could you read the
18 question.
19 (The record was read.)
20 THE WITNESS: What - sorry. I don't
21 understand that question.
22 BY MR. DEIXLER:
23 Q Okay. So you had responsibilities as a
24 member of the CMO over the ten-year time period; is
25 that correct?
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A Correct. 09:03:30 I A Yes.
Q And the -- the training which you have 09:03:31 2 Q Okay. And so that was from 2004 through
prescribed was to teach you how to do the work which 09:03:33 3 2006, as I recall; is that right? You regularly
you would be doing in the CMO. Is that true? 09:03:39 4 resided at your parents' home until you officially
A Yes. 09:03:42 5 moved in?
Q Okay. And so it was training designed, as 09:03:44 6 A Yes.
you understood it, to assist you in the performance 09:03:44 7 Q Okay. And so during that two-year-ish
of your responsibilities in the commander's 09:03:48 8 period, you had access to your parents' computer;
messenger organization; right? 09:03:51 9 correct?
A Commodore's Messenger Organization. 09:03:52 10 A Yes.
Q Commodore's Messenger Organization, yes. 09:03:53 11 Q And what did you use it for?
A Yes. 09:03:55 12 A I used it for social networking, yeah.
Q Within the Sea Org; correct? 09:04:02 13 . Q Okay. And "social networking" meaning
A Yes. 09:04:04 14 something before April of 2008 when you had a
Q Okay. I appreciate that. 09:04:07 15 Facebook page; so that perhaps would have been a
If we were to represent to you that your 09:04:11 16 MySpace page?
Facebook page bears an opening date, first posting 09:04:12 17 A Yes.
date, of April 9th, 2008, would that be inconsistent 09:04:12 18 Q Okay. And "social networking" meaning
in any way with your memory? That is before the 09:04:14 19 communicating with your friends who had been in the
birth of your son by six-or-so weeks? 09:04:18 20 Sea Org; right?
A I think so, but I may be mixing up MySpace 09:04:20 21 A Yes.
and Facebook; so - 09:04:21 22 Q Any other use that you made of your
Q Okay. Your-- your-your general memory 09:04:24 23 parents' computer in that approximate two-year
is that whether it was Facebook or MySpace, you had 09:04:26 24 period other than the social networking?
a website or used the social networking site prior 09:04:29 25 A Not that I recall.
Page 219 Page 221
to the birth of your son. Is that fair? 09:04:29 I Q Okay. Did you ever search the Internet?
A Yes. 09:04:37 2 A I didn't, no.
Q Okay. And on that social networking site, 09:04:38 3 Q Did you ever hear of an application called
it was used, as you described yesterday, to 09:04:41 4 Google?
communicate with people whom you knew; correct? 09:04:41 5 A Yes.
A Yes. 09:04:42 6 Q Did you ever use Google?
Q Friends that you had known while you were 09:04:43 7 A For job-related things.
in the Sea Org; correct? 09:04:46 8 Q Okay. And so give me an example of how you
A Yes. 09:04:49 9 would use Google during the time that you were using
Q And so you had, from the time you left in 09:04:52 10 your parents' computer.
April of2004, certainly through, at least, April of 09:04:56 II A Let's say I was looking for a specific
2008, when your Facebook or MySpace page went up, 09:04:59 12 place. I would Google it. Or I was looking for
access to a computer; correct? 09:05:08 13 information about different Indian tribes for
A Yes. 09:05:11 14 Rick Pendery. I would Google that.
Q Okay. And it was your mother's computer or 09:05:14 15 Q Okay. Did you ever Google Scientology?
your father's? 09:05:16 16 A No.
A Different times, different computers. 09:05:21 17 Q Why not?
Q Okay. So let's -- let me try to get a 09:05:21 18 A Because that was something that was a big
small history of the computers you had access to 09:05:26 19 no-no.
from the time you left the Sea Org. 09:05:29 20 Q It was a big no-no.
What was !)le first computer you had regular 09:05:31 21 Had someone told you not to use Google to
access to? 09:05:33 22 search the term "Scientology"?
A My parents' computer. 09:05:37 23 A Yes.
Q Okay. Mom and dad's computer at the -- at 09:05:38 24 Q Who told you that?
their house where you were living; correct? 09:05:39 25 A Andreas Rodriguez.
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Q When? 09:08:16 I time you were in the Sea Org?
A lnRPF. 09:08:18 2 A Not that I recall.
Q
When in the RPF? 09:08:19 3 Q
Okay. So when is the first time you
A 200(}- - this is a total guess. Some- - 09:08:21 4 remember using a computer and searching on the
sometime in 2002, 2003. 09:08:24 5 Internet?
Q
Okay. And who else was present at the time 09:08:34 6 A I used - like I said, when I was at my
you received this instruction? 09:08:37 7 grandma's house in 2001, I used the computer to book
A No one. 09:08:42 8 a plane ticket. That was pretty much the first lime
Q
Okay. Just the two of you? 09:08:45 9 I was connected to the Internet.
A Yes. 09:08:46 10 Q
Okay. And after you left the Sea Org until
Q
Tell me, if you will, what he said to you 09:08:48 II you posted your Facebook page in April of 2008, with
and you said to him on that occasion. 09:08:53 12 what frequency did you use the Internet?
A He asked me if when I - he asked me if 09:08:56 13 A Aloi.
when I had gone up to see my grandmother in 2001 if 09:08:57 14 Q
Yeah. And you used it either in your house
I had gone on the Internet and searched Scientology, 09:09:04 15 or in your parents' house; is that true?
and I said no. I didn't even know anything about 09:09:06 16 A Yes.
Google al that point in time, and he's, all, "Oh, I 09:09:07 17 Q
Okay. You yourself had a computer after
don't believe you,
11
and I was, like- I'm, like, "I 09:09:09 18 you moved out of your parents' house?
don't even know - I don't even know how to use 09:09:12 19 A I had a computer right after I - I got out
Internet other than 1- my grandma showed me how to 09:09:14 20 of the SO because Rick Pendery bought one --
book a plane ticket," and he was, like, "Well, you 09:09:17 21 Q Okay. So--
know, you're not" - he was saying I'm - he was 09:09:17 22 A - for me to use.
kind of accusing me of having looked at things on 09:09:18 23 Q - so you had a computer and your parents
the internet that I shouldn't have, and then I was 09:09:20 24 had a computer at --
defending that saying I hadn't and he's, like, 09:09:22 25
I
A Yes.
Page 223 Page 225
"Well, just so you know, you're not allowed to 09:09:22 I Q
-- at your parents' house; correct?
search that because there is OT data and things that 09:09:24 2 A Yes.
you're not allowed to look at." 09:09:24 3
Q
Okay. And then when you stopped working
Q
Okay. And "OT data" is -- is what? 09:09:26 4 for Mr. Pendery, did you return the computer to him?
A Operating Thetan. It's confidential 09:09:30 5 A I gave it to Derek Baxter who was working
materials in the Church of Scientology. 09:09:33 6 ro"r him.
Q
Okay. And it's a higher level on the 09:09:34 7 Q
Okay. And did you get another computer
Bridge to total freedom; is that right? 09:09:36 8 after that one?
A Yes. 09:09:37 9 A Yes.
Q
Okay. And you hadn't yourself reached that 09:09:38 10
Q
Okay. And that was your own computer?
higher OT level? 09:09:41 11 A Yes.
A Correct. 09:09:41 12 Q
,And where were you living at the time you
Q
Okay. Did Mr. Rodriguez say anything else 09:09:42 13 got this next computer?
to you on this topic on that occasion? 09:09:44 14 A At my parents' still.
A No. 09:09:51 15 Q
Okay. During the time that you had the
Q
Did anybody else make a similar statement 09:09:52 16 computer from Mr. Pendery, did you ever search the
to you during the time that -- prior to your posting 09:09:55 17 Internet?
your Facebook page in April of2008? 09:09:58 18 A I think I answered that already.
A It was a known thing. I don't know how to 09:09:59 19
Q
I'm sorry if you did. Would -- would you
explain it other than it was a known thing when I 09:10:01 20 remind me of the answer.
was in Sea Org but - 09:10:02 21 MR. BLUMBERG: What she already said was
Q
When you were in Sea Org, did you use a 09:10:03 22 she used it to look up Indian tribes for
computer? 09:10:07 23 Mr. Pendery.
A Yes. 09:10:08 24 THE WITNESS: Yeah. For job-related
Q
Did you ever use the Internet during the 09:10:09 25 things.
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BY MR. DEIXLER: 09:12:43 I nonobjection that you've reconsidered your legal
Q
Okay. Any other purpose other than looking 09:12:50 2 position and you're not going to by to invoke this
up Indian tribes or addresses? 09:12:55 3 quasi-spousal privilege that you were talking about
A For searches, no.
09:12:56 4 yesterday?
Q
Okay. Never did a Google search other than 09: 12:57 5 Is that a fair assumption, that you've
for an Indian tribe or for an address; is that 09:12:57 6 withdrawn that objection?
correct? 09:12:57 7 MR. BLUMBERG: I've withdrawn the objection
A I'm sorry. I don't remember every Google 09:12:59 8 to the quasi-spousal privilege because I don't
search that I did. 09:13:02 9 believe that there is one, but that does not mean
Q
Okay. Did you have a television during the 09:13:06 10 that matters that still are protected by privacy
time you lived with your parents? 09:13:13 II interests are -- are waived, but with regard
A Yeah. Off and on. 09:13:15 12 specifically to -- to the question of the
Q
Okay. Did you have a radio? 09:13:18 13 quasi-spousal privilege, yes, I'm withdrawing it.
A Yeah. 09:13:21 14 BY MR. DEIXLER:
Q
Did you have a car? 09:13:23 15 Q So let me ask you about your conversations
A Yeah. 09:13:25 16 with Daniel as they pertain to the
Q
Did the car have a radio? 09:13:28 17 Church of Scientology.
A Yeah. 09:13:34 18 You -- he was not a Scientology believer;
Q
Okay. Did your parents read a newspaper? 09:13:38 19 correct?
A No. 09:13:38 20 A Correct.
Q
No newspaper delivered to the house? 09:13:39 21 Q And he was well aware of your involvement
A No. 09:13:41 22 in the church over the long period of time when
Q
Okay. Did you ever read a newspaper from 09: 13:44 23 first you met; correct?
the time you left the Sea Org until the time you 09:13:45 24 A Yes.
first posted your Facebook page in April of2008? 09:13:45 25 Q Okay. That was something that you shared
Page 227 Page 229
A I - probably. 09:13:47 1 with him; correct?
Q Okay. 09:13:48 2 A That I was a Scientologist, yes.
MS. SMOLOWITZ: Again, don't speculate. 09:13:52 3
Q
Okay. And that you remained a
Just answer the question. 09:13:54 4 Scientologist; correct?
THE WITNESS: I don't -- nothing stands 09:13:56 5 A Yes.
out. You know, I didn't ever sit down to read a 09:13:56 6 Q Okay. And part of what you hoped to do was
newspaper. I don't -- Daniel does. I don't. 09:13:59 7 to interest him in your religion; correct?
BY MR. DEIXLER: 09:14:01 8 A I - I was trying to get his interest in
Q Okay. Did Daniel have a newspaper in the 09:14:04 9 Scientology, yes.
house starting in '06 when you were together? 09:14:05 10 Q And in order to get his interest in
A No. 09:14:07 II Scientology, did you give him any books or videos to
Q So you don't -- he doesn't subscribe to a 09:14:10 12 look at?
newspaper, to the best of your knowledge? 09:14:19 13 A My dad sat down with him at one point. I
A No. 09:14:21 14 didn't give him any books, no.
Q Okay. As of April of2008, had you heard 09:14:26 15 Q Or show him any videos?
anything negative about the Church of Scientology? 09:14:28 16 A No.
A In 2006 or whenever it was that Anonymous 09:14:28 17 Q Can you recall any discussions you had with
did that first video. 09:14:29 18 him where you tried to explain to him the benefits
Q Uh-huh. What did you hear about that? 09: 14:32 19 of Scientology?
A Daniel told me that he saw it online, and I 09:14:33 20 A Yes.
immediately went into defense mode and said "Don't 09: 14:33 21 Q Okay. About how many such conversations
watch that," and I'm sure he probably did but- 09:14:36 22 did you have with him?
Q What else did Daniel tell you? 09:14:37 23 A I - I - it would all be a guess at this
A At that time I don't remember. 09:14:51 24 point. It came up several times over a few years.
MR. DEIXLER: I infer from the fact of 09:14:54 25 Q
Okay. Five or more times?
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I intended; so if you could answer that.
2 THE WITNESS: I heard "to not have
3 abortions," but --
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4 MR. BLUMBERG: Yeah. I heard - I heard --
S THE WITNESS: I heard "to not have
6 abortions," but --
7 MR. BLUMBERG: Yes. There was a word "not"
8 in there.
9 THE REPORTER: Oh, I'm sorry. And yes, it
I 0 is in here. I'm sorry. Yeah.
11 MR. DEIXLER: Okay. In that case, I'll
12 withdraw the "not."
14 BY MR. DEIXLER:
l S Q As of 1997 or 1998, you learned that there
16 had been public criticism of the
17 Church of Scientology for convincing its Sea Org
18 members to have abortions. Is that true?
19 A I heard that there was Astra Woodcraft,
20 yes.
21 Q Okay. And when you learned of that fact,
22 you had in mind your own abortion; correct?
23 A Yes.
24 Q Okay. You hadn't forgotten that-- that
2S you had had an abortion; correct?
Page 251
09:39:09 I A No.
09:39:09 2 Q Okay. And do you remember, in the context
09:39:11 3 of learning about this public criticism of being
09:39: 16 4 convinced to have an abortion, discussing that with
09:39:20 5 anybody?
09:39:20 6 A No.
09:39:24 7 Q Thinking about it yourself?
09:39:29 8 A That'd be presumption on my part, but I'm
09:39:32 9 sure - no. I don't remember.
09:39:33 10 Q Okay. So let's go back to -- to Anonymous,
09:39:37 11 if we can.
09:39:50 I 2 What was -- well, did you learn that there
09:39:54 13 came a time when the criticisms of Anonymous
09:39:S8 14 stopped?
09:39:S8 IS A I -- I don't know.
.---t------
09: 39: 59 16 Q Okay. Do you know over what period of
09:40:00 17 time, starting in about 2006, that Anonymous was
09:40:04 18 offering its criticisms of the church?
09:40: 12 19 A No. It was sometime in 2006 before I had
09:40: IS 20 Kylie.
09:40:IS 21 Q Okay.
09:40: 15 22 A I remember that.
09:40:16 23 Q Okay. And the source about the criticisms
09:40:20 24 of Anonymous was Daniel; correct?
09:40:23 25 A Yes.
Page 252
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I Q Okay. And did you discuss with any fonner
2 Sea Org member what you had learned from Daniel?
3 A No.
4 Q Weren't you interested in learning more
5 about it?
6 A No.
7 Q Weren't you interested in defending your
8 faith, if necessary?
9 MR. BLUMBERG: Objection. The question's
I 0 vague, ambiguous, overbroad, and misleading.
11 THE WITNESS: I was - I don't even
12 understand how to answer that. Like, what --
13 MR. BLUMBERG: If you don't understand--
14 THE WITNESS: I don't understand.
15 BYMR.DEIXLER:
16 Q Okay. In 2006 you didn't seek to learn
17 more about the criticisms of Anonymous other than
18 what Daniel had told you; correct?
19 A Correct.
20 Q You -- you chose to not ask somebody either
21 at the Church of Scientology or formally at the
22 Church of Scientology, as a Sea Org member, about
23 the underlying controversy; is that true?
24 A I did not choose. I didn't think about it
25 at the time.
Page 253
I Q Okay. So now let me turn your attention to
2 April of2008. You start a Facebook page; correct?
3 A I think I had a Facebook page before then.
4 Q Okay. And if not a Facebook page, then
S certainly a MySpace page; correct?
6 A Yes.
7 Q And so during all that time, you had
8 Internet access; correct?
9 A Yes.
10 Q Okay. So we were earliertalking a little
11 bit about it. I want to make sure I understand all
I 2 of the computers that you owned during the time.
13 You had the one from work; you had your mom
14 and dad's; then you had a computer which you bought.
IS Was that a laptop or a PC or a Mac or --
16 A A laptop.
17 Q And that was one that was first at your
18 parents' house and then transported to your new
19 residence, or was it only at your new residence?
20 A It was at both.
21 Q Okay. And do you still have that computer?
22 A Yes.
23 Q Okay. And have you deleted any information
24 from it?
2S A No.
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I Q Okay. So whether your father was at the
2 bookstore or doing something else on a regular
3 basis, you just didn't know; correct?
4 A I knew that he was going into the - in
5 there most days.
6 Q Okay. And in addition to going in there, I
7 guess the bookstore office, most days, did he have
8 any other employment or vocation that he was
9 pursuing?
10 A I don't- at thattime I don't know.
11 Q Okay. In the period 2004 or 2005, did you
12 ever have a conversation with your dad where you
13 said something like "Hey, dad, what do you do all
14 day?" or words to that effect?
15 A No.
16 Q Or "Where have you been?;' or "Having a nice
17 day?" or any of those kinds of things?
18 A "How's your day?" sure.
19 Q Okay. And would he tell you "It was great.
20 I was playing golf all day" or "I was in the
21 bookstore." Or what -- what kinds of reports would
22 he give you about what he had done during the day?
23 A It wasn't reporting. It was "Oh, good."
24 Q And that would be the end of it?
25 A Yeah.
Page 259
I Q Your dad's not much of a talker?
2 A No.
3 Q Okay. Let's -- let's ask about your
4 mother. When she was the HCO exec sec, was that a
5 full-time undertaking?
6 A I don't know her hours when she worked
7 there.
8 Q Okay. You didn't notice that she was out
9 of the house most days most of the day?
I 0 A Atthe time I probably noticed. It's not
11 something of significant importance to me; so I
12 don't remember.
13 Q Okay. Was she also involved in the
14 melaleuca business while she was serving as the HCO
15 exec sec?
16 A I think so. I think she was still doing
17 some.
18 Q Okay. Now, you had related to your parents
19 your experiences as a Sea Org member; is that true?
20 During this period of 2004 and 2005 when they were
21 giving service to the Albuquerque church is the
22 period I had in mind.
23 MR. BLUMBERG: I'll object to the question
24 as vague and overbroad.
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I BY MR. DEIXLER:
2 Q Answer my question, please.
3 A I had spoken to my mother about the thing
4 that I mentioned yesterday where I told her that I
5 was not actually pregnant in 2001.
6 Other than that, no, I did not speak to her
7 about my experiences in the Sea Org.
8 Q Ever?
9 MR. BLUMBERG: Are we up to -- are we
I 0 talking about the 2008?
11 MR. DEIXLER: Yes. That's the per- -- no.
12 Not 2008.
13 Q In 2004 to 2005 period when your parents
14 were active giving service to the Church of
15 Scientology, did you ever tell them about any of
16 your experiences in the Sea Org during that time
17 period?
18 A I told them -- I don't remember. Honestly,
19 I did not - I did not complain about it, if that's
20 what you're trying to get at.
21 Q Okay. You didn't tell them, for example,
22 that you had been persuaded against your wishes to
23 have an abortion?
24 A No, I did not say that.
25 Q Okay.
Page 261
I A At that time.
2 Q You didn't tell them that you had been held
3 against your will at the RPF?
4 A I did not tell them that I didn't feel
5 that way at that time.
6 Q You didn't - as of2004, 2005, you didn't
7 feel you had been held against your will?
8 A No.
9 Q You believe as of2004, 2005, you had
I 0 volunteered to go to the RPF; correct?
11 A I believed that I thought that it was the
12 greatest good for me to do it at that point.
13 Q And you later changed your mind about it?
14 A Yes.
15 Q Okay. And when did you change your mind?
16 A In 2008 when I started opening my eyes to
17 things that I hadn't looked at before.
18 Q Okay. So let's start there in the middle
19 part of June of2008. Your mother's computer was on
20 her desk. The computer was on, and what did you
21 first see on the computer?
22 A I do not recall what I was going to her
23 computer to do. I saw a minimized screen saying
24 "Ex Scientologist Message Board."
25 Ill 09:52:28 25 Q Okay. And what did you do when you saw
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I that?
2 A I opened it up and I said "Mom, what is
3 this?"
4 Q Okay. Why did you open it up?
5 A Because I was, like - what - "What is
6 this?" I didn't know what it was.
7 Q And did you read it?
8 A Not at that time.
9 Q Okay. Doyourememberthenameofthe
I 0 particular message board or website that you were
11 looking at?
12 A "Ex Scientologist Message Board."
13 Q Okay. And did you read the posting?
14 A No.
15 Q So after the Ex Scientologist Message Board
16 was maximized, what do you remember reading on it?
17 A I read the tide. Ex Scientologist Message
18 Board.
19 Q And then you stopped reading?
20 A And then I stopped.
21 Q You weren't curious to see what was being
22 said?
23 A At the time that this happened, I went into
24 immediate flip of the switch, I'm - I was, like,
25 "Mom, what on earth is this? What are you doing?"
Page 263
I Q So you were curious to find out what was --
2 A No. I was accusing my mom oflooking at
3 something that she shouldn't be looking at.
4 Q Why did you think that if you didn't look
5 at the content of it?
6 A Because it was an Ex Scientologist Message
7 Board.
8 Q And so the fact that it was an
9 Ex Scientologist Message Board caused you to think
I 0 that it was -- contained criticisms of the church?
11 A You're asking my thought process at the
12 time?
13 Q Exactly.
14 A Yeah. That is what I assumed.
15 Q And why did you assume, when you looked at
16 the Ex Scientologist Message Board in mid-June of
17 2008, that it would contain criticisms?
18 A Because if you're announcing that you're an
19 ex-Scientologist - if you're announcing that you're
20 an ex- - it's a crime in Scientology to publicly
21 say that you've left Scientology. It's listed in
22 their crimes and high crimes.
23 Q Okay. So you believed that by seeing the
24 title, you -- the substance of what was contained
25 underneath it would be evidence of high crimes. ls
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I that fair?
2 A Yes.
3 Q Okay. And you didn't want to read evidence
4 of high crimes; correct?
5 A That's altering my -- my thought process
6 because that's not what I was thinking. I wasn't
7 thinking, "Oh, this is evidence of high crimes." I
8 was thinking "This is a critical side of
9 Scientology. What are you doing on it?"
10 Q Okay. And as of the time in mid-June,
11 2008, you had heard from your husband, from the
12 articles that you heard about in "Time" or
13 "Newsweek" magazine and about Miss --
14 A Woodcraft.
15 Q -- Woodcraft's criticisms that there were
16 public criticisms of the Church of Scientology;
17 correct?
18 A Yes.
19 Q Okay. And so you weren't surprised to
20 learn that there were.websites or message board
21 postings which were critical of the church; correct?
22 A I was surprised that there was a forum. I
23 had no idea.
24 Q Okay. Had you yourself ever participated
25 in any forum on the Internet --
Page 265
I A Yes.
2 Q -- on any topic?
3 What kinds of fora had you participated in?
4 A Baby Center.
5 Q And for about how long had you participated
6 in forums on Baby Center?
7 A When I became pregnant with Kylie.
8 Q So 2006?
9 A Yeah.
10 Q Okay. And did you participate on -- on
11 Baby Center for a regular period of time from 2006
12 forward?
13 A 2006 until shortly after I had Kylie.
14 Q Okay. So until perhaps December of2007?
I 5 Maybe January?
16 A Something like that.
17 Q Okay. And what was your screen name?
18 A I think it's ldc2500. It still exists. I
19 posted couple random times since then but -
20 Q Okay. And what other fora were you active
21 in?
22 A What is that word? For -
23 Q It's -- it's -- it's the plural of forum.
24 A Oh, okay.
25 MR. BLUMBERG: It is?
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I MS. SMOLOWITZ: It's forums.
2 MR. BLUMBERG: Yeah. Just -- tha(s what
3 he means, whether it's correct or not, so you're not
4 confused.
5 THE WITNESS: You're asking me what other
6 forums have I written on or -- or --
7 BY MR. DEIXLER:
8 Q Yes. And I'll adopt your word.
9 A Okay. In - in mid- - I think May,
10 2000- -yeah, May, 2007, some of the girls from the
11 December Baby Board group that I was on created
12 their own forum, and I've been on that one off and
13 on for - since then.
14 Q ls that kind of a renegade Baby Board
15 group?
16 A Yes.
17 Q Okay. And you're a member of that?
18 When did that start?
19 A May, 2007.
20 Q Okay. Did you know the
21 Church of Scientology had a website?
22 MR. BLUMBERG: I'm sorry. I'm sorry. Can
23 you put it in the time frame? We've kind of been --
24 been jumping time frames, and I'm not sure which
25 time frame we're in right now.
Page 267
I BY MR. DEIXLER:
2 Q Okay. From the time you participated for
3 the first time in the Church of Scientology until
4 April of2008, when you had a Facebook page, did you
5 know the Church of Scientology had a website?
6 A Yes.
7 Q Okay. Had you ever visited the
8 Church of Scientology website?
9 A I think I may have. I don't know. Maybe.
I 0 Q Do you recall approximately when you
11 visited the Church of Scientology website?
12 A I don't- I honestly don't remember. I
13 think I've seen it. Whether it was before or after,
14 I don't know.
I 5 Q Before or after what?
16 A Before or after I left Scientology.
17 Q Okay. But you don't have any particular
18 memory of anything that you read on the website?
19 A No.
20 Q But you were certainly aware that there was
21 a website, whether you visited it or not; correct?
22 A Yes.
23 Q How did you learn that?
24 A When I was in the Sea Org.
25 Q Okay. Before you were on the RPF?
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1 A Yes.
2 Q Okay. So before 2001, you were aware that
3 the Church of Scientology had a website; correct?
4 A Yes.
5 Q And you don't recall any specific instance
6 ever visited that website. Is that true?
7 A No.
8 Q It's not true or it is true?
9 A 1- I don't recall.
IO Q Okay. You might have, and you've
I 1 forgotten?
12 A Right.
13 Q Are there other forums that you visited
I 4 before you visited the Ex Scientologist Message
15 Board?
16 MR. BLUMBERG: I'm sorry. The question is
17 ambiguous about -- are you talking about any forums
18 in the world?
19 BY MR. DEIXLER:
20 Q Could you answer my question?
21 A Are you asking if I participate in - in
22 forums or - or what is the -
23 Q Well, you talked about Baby Center. You
24 talked about Baby Board. We talked a little bit --
25 beginning to talk about it - the Ex Scientologist
Page 269
1 Message Board, and I'm trying to see ifthere are
2 other similar kinds of message boards that you
3 reviewed, commented in, or had any other dealings
4 with.
5 A Not that I remember.
6 Q Okay. So it would be Baby Board and Baby
7 Center and -- before you went to the
8 Ex Scientologist Message Board and maximized the
9 minimized screen. Is that fair?
10 A Yes.
11 Q Okay. Andyourmemoryisthatyoujust
12 read the title and you didn't read anything below
13 the title; is that true?
14 A That's true.
15 Q But from the title, you concluded that this
16 was critical of the Church of Scientology; correct?
17 A Yes.
18 Q And you asked your mother, in effect, "What
19 the heck is going on here?"
20 A Yes.
21 Q Okay. And how long after that conversation
22 with your mother was it before you again visited an
23 Ex Scientologist Message Board or reviewed such a
24 publication?
25 A It was later that night, I believe. Unless
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I it was the next day. I don't - that's a little
2 mushed there.
3 Q Okay. But mid-June, 2008, after first
4 seeing the message board, reading only its title,
S you went back and visited it -- visited an anti --
6 or - or an Ex Scientologist Message Board; correct?
7 A Yes.
8 Q Okay. Was it the same one you had seen
9 earlier that day or a different one?
10 A Three In total.
11 Q Three Ex Scientology Message Boards that
12 night?
13 A It was - it was either that night or the
14 next day. I - it's unclear to me which.
I 5 Q How did you find those sites?
16 A My mom told me about them.
17 Q Okay. And what sites do you recall
18 visiting?
19 A Ex-Scientology message board --
20 Ex Scientologisl Message Board, Ex Scientology Kids,
21 and Why We Protest.
22 Q Okay .. And do you have a -- a memory of the
23 content of each one separately, or do the three
24 message boards that you reviewed in mid-June of2008
25 tend to blend together in your memory?
Page 271
I A I remember different stories from different
2 boards.
3 Q Okay.
4 A Mainly the Ex-Scientology message board and
S the Ex Scientology Kids message board.
6 Q Okay. So what particular message can you
7 recall first reading or the first visit you had to
8 the ex-Scientology message board?
9 A I remember trying to find anything that was
I 0 written by Jenna or Amy -- Jenna Miscevige or
11 Amy Harrison/Amy Allen. What, I do not remember the
12 content, exactly, but I remember I was looking for
13 anything about them.
14 Q Did you know either of them when you were
IS in the Sea Org?
16 A Yes.
17 Q Okay. Were they friends of yours?
18 A Yes.
19 Q Okay. And you knew they had left the
20 Sea Org?
21 A I did not know until then that - I don't
22 think I knew about either of them being out until
23 then.
24 Q Okay. And what caused you to look for
25 Jenna and Amy as opposed to any of the other people
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Page 272
I that you might have been once in Sea Org with?
2 A Because my mom had mentioned that Jenna,
3 Amy, Astra, and somebody else named Kendra had
4 started the Ex Scientology Kids message board.
5 Q Okay. That's different from the
6 ex-Scientology message board, isn't it?
7 A Yes.
8 Q Okay. So you wanted to check to see
9 whether Jenna, Amy, and, I guess, Kendra had also
I 0 posted on the ex-Scientology message board?
11 A No. I didn't know Kendra. My mom had just
12 mentioned -
13 Q !see.
14 A - that she was one of the people who had
15 started it.
16 Q Okay. So can you recall the substance of
17 anything you read that night or the next day that
18 had been posted on the ex-Scientology message board?
19 A I remember reading - I'm - I'm sorry. I
20 don't remember the exact posts that I read at that
21 time.
22 Q What was the substance?
23 A I read the introduction-type thing. The
24 s.tory that - I don't know if Astra or Jenna wrote
25 it at the beginning, I think. It's, like, on the
Page 273
I "About Us" page type thing. I read -
2 Q And -- and tell me, if you would, what you
3 remember about that.
4 A Just that it was a group of people who had
5 previously grown up in Scientology and were no
6 longer in Scientology, and there were videos of
7 Jenna speaking to somebody. I don't know if ii was
8 a news thing or -- or just a video.
9 There was a video of Amy speaking to, I
10 believe, a news thing, and Astra, and they were
11 talking about the whole subject of -- Astra brought
12 up the whole subject of kids. I don't remember what
13 Amy's exactly covered. Sorry. I - I don't
14 remember.
15 Q And - and Jenna's? Do you recall what
16 that covered?
17 A I don't remember what she said in it.
18 Q Okay. Do you remember thinking, as you
19 listened to this, that "Some of what they are
20 talking about happened to me or is similar to my
21 experience"?
22 A I definitely remember feeling that way when
23 I was reading things on the boards.
24 Q Right.
25 And about how much time did you spend on
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this first board, the ex-Scientology message board? 10:09:39 I who had been through something together; is that
A Ex Scientology Kids? 10:09:41 2 right?
Q No. Ex Scientology -- we were going 10:09:42 3 MR. BLUMBERG: I'm going to object. The
through the ex-Scientology board first. Then we 10:09:43 4 question is vague and ambiguous.
were going to talk about Ex Scientology Kids 10:09:52 5 THE WITNESS: I felt that -- sorry. Can
perhaps. 10:09:53 6 you ask the question again?
A Oh, I was talking about 10:09:54 7 BY MR. DEIXLER:
-
Ex Scientology Kids. 10:09:55 8 Q
You felt a community with these former
Q
Okay. Then we'll -- we'll incorporate that 10:09:58 9 Scientologists; correct?
by reference. Was - was that the first of the 10:10:01 10 A Yes.
three that you looked at that night? 10:10:02 II Q
Okay. And -- and that made you feel like
A Yes. 10:10:10 12 part of a group again. Is that true?
Q
Okay. So you recall thinking to yourself 10:10:12 13 A Not at that point.
that some of the things which were being described 10:10:13 14 Q No?
by Arna -- Amy and Jenna and Astra "were things that 10:10:14 15 Were you, at the instant that you were
happened to me too"; correct? 10:10:17 16 reading it that night, still a Scientologist?
A Yes. 10:10:27 17 A No.
Q
And do you remember thinking that you 10:10:27 18
Q
Okay. So by mid-June, 2008, you didn't any
wanted to read more about this? 10:10:30 19 longer consider yourself a Scientologist; correct?
A Yes. 10:10:33 20 A Right.
Q
Okay. And did you read more about it after 10:10:34 21
Q
For how long before reading this
you went by that introductory page? 10:10:39 22 information on the computer screen in mid-June,
A Yes. 10:10:41 23 2008, had you no longer considered yourself a
Q
Okay. What else did you remember reading 10:10:45 24 Scientologist?
that night? 10:10:47 25 MR. BLUMBERG: Objection. It misstates her
Page 275 Page 277
A I don't remember. 10:10:48 I testimony.
Q
Okay. Or would it be fair to summarize 10:10:50 2 THE WITNESS: That - the day that my -- I
them as criticisms of the Church of Scientology? 10:10:53 3 sat down with my parents, which we discussed in the.
A It was - it'd be fair to say that they 10:10:56 4 prior deposition.
were the stories of things that had happened to 10:10:57 5 BY MR. DEIXLER:
people when they were in Scientology. 10:10:57 6
Q
Okay. So this viewing occurred either that
Q
Okay. And they were in the nature of bad 10:11:05 7 night or the next night after you and your parents
things that happened; correct? 10:11:07 8 had their conversation with you; correct?
A Yes. 10:11: 10 9 A Yes.
Q
Okay. And some of those bad things that 10:11:11 10
Q
Okay. So at that instant in mid-June of
were described were things that you yourself 10:11:14 II 2008, you were no longer, in your mind, a
experienced; correct? 10:11:18 12 Scientologist; correct?
A Yes. 10:11:20 13 A Yes.
Q
Okay. And so as you read this, you thought 10:11:20 14 Q
Okay. So when you looked at the website,
"This reflected some of the issues that I myself 10:11:26 15 Ex Scientology Kids, you were no longer, in your
confronted when I was in the Sea Org"; correct? 10:11:29 16 mind, a Scientologist; correct?
A Yes. 10:11:31 17 A Right.
Q
Okay. And you felt sympathetic toward the 10:11:32 18
Q
You were at that instant a former
people who were posting and telling the stories on 10:11:35 19 Scientologist; correct?
the video portion; isn't that true? 10:11:37 20 A Yes.
A I don't recall. 10:11:37 21 Q
Okay. And you had conveyed that only to
Q
You felt a kinship with them? 10:11:39 22 your parents; correct?
A Yes. 10:11:40 23 A Yes.
Q
Okay. A kinship that was different from 10:11:41 24
Q
Had you conveyed that to Daniel?
your having been co-religionists but rather people
-
10:11:46 25 A Yes. 1- I had told him when I came home
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I did start having nightmares at about that 11:40:23 I Q
Do you know whether your parents had
time, though. 11:40:24 2 revealed to Stephanie or Emily that they were no
Q
Stopped eating, for example? 11:40:28 3 longer Scientologists?
A No. 11:40:35 4 A My mom told me that she had talked to
Q
No longer cared for your children? 11:40:38 5 everybody but me.
A I still cared for my children. 11:40:40 6 Q
Okay. Did Emily or Stephanie ever discuss
Q
Okay. So while you suffered the harm and 11:40:46 7 with you whether some of your experiences in Sea Org
were aware of it, you kept it internalized, you 11:40:54 8 were similar to either ones they had experienced or
would say; correct? 11:40:57 9 had heard about?
A It was - yeah. It was very internalized. 11:40:58 10 A Didn't talk about it.
Q
Okay. You didn't go, as we discussed 11:40:59 II Q
Okay. So, for example, did Emily know that
yesterday, to anybody in the healthcare professions 11:41:01 12 you had had an abortion?
to talk about the issue; right?. . 11:41:04 13 A I don't know.
A No. 11:41:05 14
Q
Okay. Did she know that you had falsely
Q
Okay. You mentioned that you had 11:41:07 15 claimed to be pregnant?
conversations with your siblings on this -- on the 11:41:10 16 A Not that I know of.
topic -- well, let me make sure I understand exactly 11:41:12 17
Q
Okay. Did- did you ever tell that to
what the topic was. 11:41:13 18 Daniel?
When you spoke to Stephanie, what did you 11:41:14 19 A Yes.
talk to her about after you had seen the message 11:41:15 20
Q
Okay. And when did you do that?
board? 11:41:24 21 A I don't remember.
A I don't remember. 11:41:29 22 Q
Before or after you had children?
Q
How about Emily? 11:41:39 23 A Specifically the fact that I said I was
A I don't remember. 11:41:42 24 pregnant?
Q Okay. Do you remember telling -- were 11:41:44 25 Q
When you -- when you weren't pregnant.
Page 327 Page 329
either Stephanie or Emily in Scientology? I've 11:41 :47 I A Right. After.
forgotten. 11:41:50 2
Q
After you had both kids?
A Both. 11:41:52 3 A Yeah.
Q
Both were in Scientology. 11:41 :53 4 Q Okay. So let me return to the time period
And 'Yere they Scientologists at the time 11:41:59 5 that we've been studying in June and July of 2008.
that you had seen the board in mid-June of 2008? 11:42:04 6 Is there anybody else that you can recall
A I don't -- 1-- I don't know for certain. 11:42:06 7 having any communication with -- written or -- or
Q
Okay. They were not Sea Org members, 11:42:12 8 oral, in person, or on the telephone -- triggered by
though, were they? 11:42:17 9 the message boards which you had read?
A Not at that time. 11:42:19 10 A Sorry. I -- I have to back up because it's
Q
Okay. Had they ever been? 11:42:21 II holding my attention.
A Emily was. 11:42:22 12 I think that I told Daniel about lying
Q Okay. And did -- did Emily leave the 11:42:26 13 about being pregnant because I know - I think --
Sea Org? 11:42:30 14 I - I just don't remember the exact conversation;
A Yes. 11:42:32 15 so I'm not 100 percent certain on that one.
Q
When did she leave? Before you did or 11:42:36 16 It's -- it's holding my attention because I
after? 11:42:38 17 don't -- I'm not 100 percent certain.
A After. 11:42:41 18
Q
So you may never have told him?
Q
Okay. So sometime in 2005, 2006? 11:42:44 19 A Maybe.
A To the best of my -- what I remember, it 11:42:45 20 Q
Okay. Did -- do you remember telling him
was either end of 2004 or 2005. 11:42:50 21 that you had faked having an abortion?
Q
Okay. And you don't remember what you 11:42:56 22 That's a bad phrase.
discussed with either Stephanie or Emily after you 11:42:59 23 That you had falsely claimed that you had
had seen the message boards; correct? 11:43:01 24 had an abortion?
A No. 11:43:03 25 A I would have had to have told him that I
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I Ambiguous. Overbroad with regard to the word
2 "concerns."
3 THE WITNESS: Yeah. I'm not sure what you
4 mean by my concerns.
5 BY MR. DEIXLER:
6 Q The events that had been stirred up as a
7 result of your review of the postings. Did you, in
8 the time period between June and January, talk to
9 Daniel about it?
I 0 A I - I did speak to him about the general
11 subject. Do I remember exact conversations? No.
12 Q Okay. Do you recall, in substance, what
13 you were saying to him in that time period that
14 we're interested in?
15 A I don't have any particular conversation
16 that sticks out in my mind as "Oh, I talked to
17 Daniel about it." It wasn't -yeah.
18 Q Was your -- were the feelings that had been
19 stirred up in - in the review of the postings
20 something that persisted with you for this block of
21 time, the six-month period that we've been talking
22 about?
23 A Yes.
24 Q Okay. So all of this time, when you were
25 feeling what -- what you described earlier as harm,
Page 343
I was not a time when you spoke to the person who was
2 the father of both of your children and the person
3 with whom you were living; is that correct?
4 MR. BLUMBERG: Objection. The question is
5 argumentative.
6 BY MR. DEIXLER:
7 Q Could you answer my question, please?
8 MR. BLUMBERG: She's not going to answer an
9 argumentative question.
I 0 I instruct her not to answer.
I I BY MR. DEIXLER:
I 2 Q Okay. Your memory is that, notwithstanding
I 3 the harm that you were experiencing, that you didn't
I 4 discuss it with Daniel -- is that true? -- in the
I 5 time period we're focused on?
16 A I didn't discuss it with anybody.
17 Q During the time period, though, you began
18 to post on the Internet; is that true?
19 A Yes.
20 Q Okay. And what was your reason for posting
2 I on the Internet?
22 A To - I guess in a way I felt it
23 therapeutic.
24 Q What do you mean by "therapeutic"?
25 A To talk about it.
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I Q Okay. But -- but what does therapeutic
2 mean in that context?
3 A Meaning I felt it was relieving to me to a
4 certain extent.
5 Q Relieving the harm you were feeling?
6 A Maybe helping it in a way.
7 Q Okay. And notwithstanding the fact that
8 you were posting, you weren't discussing the issue
9 with other people other than the ones we've
10 identified; correct?
II A Right.
12 Q Okay. And when you posted, you would post
13 things without knowing exactly who the readers would
14 be; true?
15 A True.
16 Q Okay. Let me ask you to look at a posting
17 of July 22nd, 2008, and it's a multipage --
18 eight-page document, and we'll have it marked as
19 exhibit numbered I. I have a copy for your counsel.
20 MR. BLUMBERG: Just for -- just for the
21 record, Counsel, do you want to con- --
22 It's okay. You want it to be No. I? Is
23 that what you said?
24 MR. DEIXLER: Yes, I did. I thought that
25 would be fine unless you would want to have an
Page 345
I alternate numbering system. It doesn't much matter
2 tome.
3 MR. BLUMBERG: No. Irs okay.
4 MR. DEIXLER: Okay. Thanks.
5 (The document referred to was marked as
6 Defendants' Exhibit I by the Reporter.)
7 BY MR. DEIXLER:
8 Q My first question -- and you can -- in the
9 interest of time, you could probably look to whars
I 0 numbered page 4 of 8.
11 A Yeah. I saw my- my post.
12 Q And-- 3 of8.
13 A Uh-huh.
14 Q First, I note the -- so Exhibit I is a --
15 is a -- a document which you've seen before either
16 in this form or on a computer screen?
17 A Yes.
18 Q And -- and when do you think was the last
19 time you had seen this?
20 A I saw this one - I saw the documents in
21 the middle of the documents that you provided.
22 Q Okay. So you saw them the end of last week
23 for the last time?
24 A I - I saw all - all my - my posts on -
25 Q Just trying -- just trying to find out
Page 346
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Laura Ann DeCrescenzo v. Clh of Scientology International, et al.
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with you; is that correct? 11:51:09 I leave.
A That's correct. 11:51:17 2 A I don't remember.
Q
Okay. What was the business she was in at 11:51:17 3 Q
Okay.
the time? Do you know? 11:51:19 4 A Don't think so.
A What I said earlier. Same thing. Graphics 11:51:20 5 MR. DE!XLER: All right. Let's take the
for -- for movies. 11:51:20 6 lunch break. See you at I :30.
Q
Okay. So-- 11:51:23 7 THE VIDEOGRAPHER: We're going off the
A She was in between jobs at the time. 11:51:24 8 record. The time is 11 :51.
Q
Okay. So she was a -- kind of a freelancer 11:51:26 9 We're off the record.
in the graphics world? 11:51:27 10 (The proceedings were adjourned for
A At that point. I don't -- 11:51:27 II lunch from 11:51 A.M. to 1:37 P.M.)
Q
Okay. You're still friends with her? 13:37:31 12 THE VIDEOGRAPHER: We are back on the
A Yes. 13:37:32 13 record. The time is approximately I :37.
Q
Okay. And have you talked to her about 13:37:33 14 BY MR. DE!XLER:
this lawsuit? 13:37:37 15 Q
You understand your testimony continues to
A Yes. 13:37:39 16 be under oath and subject to the penalty of perjury;
Q
When was the first time you discussed with 13:37:41 17 correct?
her the possibility of bringing a lawsuit? 13:37:42 18 A Yes.
A I don't remember. I don't remember ifl 13:37:42 19 Q
Okay. We were on the subject of the period
spoke to her about it before or after I filed. 13:37:49 20 of time from June of2008 through January, 2009,
Q
Okay. Anybody else you can recall 13:37:59 21 after you had seen the postings and before you were
discussing these topics with in June or July of 13:38: 13 22 contacted by Hansa
2008? 13:38:17 23 Do you remember that time period that we
A No. 13:38:18 24 were talking about right before we broke for lunch?
Q
Okay. Who was the next person you can 13:38:21 25 A Yes.
Page 335 Page 337
remember speaking with on the topic of the -- your 13:38:21 1 Q Okay. So you have that in mind?
negative experience in the Sea Org? 13:38:23 2 A Yes.
A Hmm. Probably, that I remember, Hansa and 13:38:24 3 Q So during the time period in question, that
Amy when she came to visit me in January, 2009. 13:38:26 4 is, from June to January, who else besides the --
Q Okay. 13:38:31 5 Hansa can you recall having conversations with
A 2000- - yeah. Is that right? 2009. 13:38:37 6 pertaining to your tenure at the
Q Okay. So let me ask: From the time that 13:38:40 7 Church of Scientology?
you saw the message boards in June of2008 through 13:38:45 8 A Melanie Wagner.
January of2009, when Hansa came to visit you, did 13:38:47 9 Q Okay. Who's Melanie Wagner?
you have any discussions with any member of the 13:38:50 JO A She is someone who was in the Sea Org for a
Sea Org? 13:38:56 11 short period of time in the '90s that I knew then,
A No. 13:39:00 12 not well particularly, but I knew her and was out of
Q Okay. Did you have any discussion with any 13:39:09 13 the Sea Org and lived in Albuquerque.
person who was acting in your or said they were 13:39:13 14 Q Okay. And what were the circumstances of
acting on behalf of the Church of Scientology prior 13:39:14 15 your speaking with her? Was it first in person or
to your meeting"with Hansa? 13:39:17 16 on the phone?
A Not that I remember. 13:39:29 17 A I do not recall how I ended up getting
Q Okay. Did you receive any email 13:39:32 18 hooked up with her. I know that I met her at a park
communication from any Sea Org member during that 13:39:39 19 with our kids and - but I don't remember who -
time period? 13:39:46 20 if- I -yeah. I don't remember how that happened
(The clerk entered the room to tell us to 13:39:50 21 now.
break for lunch.) 13:39:51 22 Q Okay. Do you recall the substance of the
BY MR. DEIXLER: 13:39:54 23 conversations you had with Ms. Wagner in this time
Q Would you answer the question thars 13:39:58 24 period that we're focused on?
pending, and then we should -- I sense we should 13:40:15 25 A I just remember - we were talking about
Page 336 Page 338
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Laura Ann DeCrescenzo v. Church of Scientology International, er al.
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I Ambiguous. Overbroad with regard to the word
2 "concerns."
3 THE WITNESS: Yeah. I'm not sure what you
4 mean by my concerns.
5 BY MR. DEIXLER:
6 Q The events that had been sti1Tcd up as a
7 result of your review of the postings. Did you, in
8 the time period between June and January, talk to
9 Daniel about it?
I 0 A I - I did speak to him about the general
11 subject. Do I remember exact conversations? No.
12 Q Okay. Do you recall, in substance, what
13 you were saying to him in that time period that
14 we're interested in?
15 A I don't have any particular conversation
16 that sticks out in my mind as "Oh, I talked to
17 Daniel about it." It wasn't - yeah.
18 Q Was your-- were the feelings that had been
19 stirred up in -- in the review of the postings
20 something that persisted with you for this block of
21 time, the six-month period that we've been talking
22 about?
23 A Yes.
24 Q Okay. So all of this time, when you were
25 feeling what -- what you described earlier as harm,
Page 343
I was not a time when you spoke to the person who was
2 the father of both of your children and the person
3 with whom you were living; is that correct?
4 MR. BLUMBERG: Objection. The question is
5 argumentative.
6 BY MR. DEIXLER:
7 Q Could you answer my question. please?
8 MR. BLUMBERG: She's not going to answer an
9 argumentative question.
I 0 1 instruct her not to answer.
11 BY MR. DEIXLER:
12 Q Okay. Your memory is that, notwithstanding
13 the harm that you were experiencing, that you didn't
14 discuss it with Daniel -- is that tnie? -- in the
15 time period we're focused on?
16 A I didn't discuss it with anybody.
17 Q During the time period, though, you began
18 to post on the Internet; is that t111e?
19 A Yes.
20 Q Okay. And what was your reason for posting
21 on the Internet?
22 A To - I guess in a way I felt it
23 therapeutic.
24 Q What do you mean by "therapeutic"?
25 A To talk about it.
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I Q Okay. But - but what does therapeutic
2 mean in that context?
3 A Meaning I felt it was relieving to me to a
4 certain extent.
5 Q Relieving the harm you were feeling?
6 A Maybe helping it in a way.
7 Q Okay. And notwithstanding the fact that
8 you were posting, you weren't discussing the issue
9 with other people other than the ones we've
10 identified; correct?
II A Right.
12 Q Okay. And when you posted, you would post
13 things without knowing exactly who the readers would
14 be; true?
15 A True.
16 Q Okay. Let me ask you to look at a posting
17 of July 22nd, 2008, and it's a multipage --
18 eight-page document, and we'll have it marked as
19 exhibit numbered I. I have a copy for your counsel.
20 MR. BLUMBERG: Just for -- just for the
21 record, Counsel, do you want to con- --
22 It's okay. You want it to be No. I? Is
23 that what you said?
24 MR. DEIXLER: Yes, I did. I thought that
25 would be fine unless you would want to have an
Page 345
I alternate numbering system. It doesn't much matter
2 to me.
3 MR. BLUMBERG: No. It's okay.
4 MR. DEIXLER: Okay. Thanks.
5 (The document referred to was marked as
6 Defendants' Exhibit I by the Reporter.)
7 BY MR. DE!XLER:
8 Q My first question -- and you can -- in the
9 interest of ti(lle, you could probably look to what's
I 0 numbered page 4 of 8.
11 A Yeah. I saw my- my post.
12 Q And-- 3 of8.
13 A Uh-huh.
14 Q First, I note the -- so Exhibit I is a --
15 is a -- a document which you've seen before either
16 in this form or on a computer screen?
17 A Yes.
18 Q And -- and when do you think was the last
19 ti me you had seen this?
20 A I saw this one - I saw the documents in
21 the middle of the documents that you provided.
22 Q Okay. So you saw them the end of last week
23 for the last time?
24 A I - I saw all - all my - my posts on -
25 Q Just trying -- just trying to find out
Page 346
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1 Did I read that correctly?
2 A. You did.
3 Q. On Page 11, right across from that.
4 "Dr. Egilman then cites a December 2004 NIOSH health
5 hazard evaluation report."
6 A. Whoa. I thought you were going to complete
7 that paragraph that you just read.
8 Q. I will if you want me to.
9 A. I don't care .. I get lost there, and you can
10 _go -- don't do anything for my behalf. Just keep reading.
11 Wherever you like to read from. No problem.
12 Q. Okay. I'll go to that paragraph.
13 "Dr. Egilman then cites."
14 A. Go right ahead. Don't do it on my account. I
15 just got lost.
16
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24
Q. Okay.
"Dr. Egilman then cites a December 2004 NIOSH health
hazard evaluation report for one popcorn -plant" --
A. No, no. T h a t ' ~ not what's following. What's
following is according to Dr. Egilman, the Kreiss article
states that.
Q. I thought you told me to go where I wa.nted to
go.
A. I thought you said -- no, do whatever you like.
25 Where are you reading from? I'm sorry.
26 Q. I'll go back there.
27 A. No, that's okay. Go where you're going. It
28 doesn't matter. You know, snippets of snippets. So it's a
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Laum Ann DeCrescenzo v. Church of Scientology International, et al. Laura Ann Dieckman - Volume 2
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'll
""' ----
saying that's one part of emotional distress. 14:47:12 I correct, do you?
Q
That's one part of it. Okay. 14:47:14 2 A I know that's not correct.
Then focusing on that same unhappiness part 14:47:15 3
Q
Okay. The rest of this post-- is that
that you testified in 1999, did you have that same 14:47:18 4 something that you wrote?
unhappiness part in 1998? 14:47:19 5 A I did write it. It's written by my - my
A I don't know. 14:47:22 6 user name, yes.
Q
How about in 2000? 14:47:24 7
Q
In the second paragraph, you say:
A I thought I already said 2000. 14:47:34 8 "During my time in the Sea Org I
Q
Did you have it in 2000? 14:47:36 9 got married and not too long after
A Honestly, I feel confused right now. I 14:47:38 10 that, I got pregnant. I spent" --
really do not understand what your - what your 14:47:40 II MR. BLUMBERG: Wait. Wait. You either
question - are you asking me - I don't know. I 14:47:41 12 have a different copy or --
don't know. 14:47:43 13 THE WITNESS: No. He's reading right
Q
When you were on the RPF, did you 14:47:44 14 there.
experience unhappiness, in the fashion in which you 14:47:45 15 MR. BLUMBERG: No. The words aren't
did, as you've testified, in 1999? 14:47:46 16 matching up.
A I experienced unhappiness in RPF, yes. 14:47:47 17 MR. DEIXLER: They're not? Maybe I should
Q
In the same way you had in 1999; correct? 14:47:49 18 look at your copy.
A No. 14:47:54 19 "During my time in the Sea Org I
Q
How was it different? 14:47:56 20 got prepared and not too long after
A I was in the RPF. 14:47:57 21 that I got pregnant."
Q
Okay. And the level or the degree of 14:47:59 22 Seems to be exactly what I was reading.
unhappiness was greater than 1999, the same, or -- 14:48:01 23 MR. BLUMBERG: I think that maybe you
or less so? 14:48:02 24 missed a word or maybe I did. We're not -- we're
A I don't know. 14:48:05 25 not trying to be conspiratorial here. I heard it
Page 87 Page 389
Q
What are the decks? 14:48:09 1 differently than I read it.
A The decks is when you are - gotten to do 14:48:11 2 MR. DElXLER: Ah. Well, you -
manual labor on the whatever building or - that 14:48:11 3 MR. BLUMBERG: And you were reading it kind
you're working in or that type of thing. 14:48:12 4 offast. Not a personal insult.
Q
Did you ever do manual labor on the decks? 14:48:16 5 MR. DEIXLER: Oh, believe me, you can't
A Yes. 14:48:18 6 insult me. No problem.
Q
Did you ever refuse to do manual labor on 14:48:21 7
Q We are on the second paragraph where it
the decks? 14:48:23 8 says:
A I refused to scrub a dumpster with a 14:48:23 9 "During my time in the Sea Org I
toothbrush. 14:48:26 IO got married and not too long after
Q Okay. Any- -- anything else you refused to 14:48:27 II that I got pregnant. I spent," all
do in the nature of manual labor on the decks?
'
14:48:29 12 caps, "HOURS upon hours being,"
A I don't know. 14:48:31 13 quote, "'handled' to have an
Q
Okay. Let me ask you to take a look at 14:48:34 14 abortion."
exhibit which we'll number 4 with a copy to your 14:48:35 15 You see the word "handled" in quotes?
lawyer. 14:48:37 16 A Yes.
(The document referred to was marked as 14:48:37 17 Q What does it mean?
Defendants' Exhibit 4 by the Reporter.) 14:48:39 18 A Forced.
BY MR. DEIXLER: 14:48:39 19 Q Okay. And - so when the word "handled" is
Q And to begin with, the very first page says 14:48:48 20 used in Scientology lexicon, it means forced? Is
"Ex Scientology Kids," and the top post dt2000, 14:48:52 21 that how you understood it?
dated July 26, 2008 -- thats you; correct? 14:48:53 22 A No.
A That is me. 14:48:54 23
Q
Okay. Were you -
Q
Okay. And the same question about the 14:48:55 24 A How I meant it there.
time -- it says 4:50 AM. You don't think that's
\,-l---j:j:48:57 25
Q
Okay. Were you given a choice about having
Page 388 Page 390
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EXHIBIT 4
Laura Ann DeCrescenzo v. C!h of Scientology International, et al. Laura Ann Dieckman - Volume 3
FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
LAURA ANN DeCRESCENZO,
Plaintiff,
v.
CENTER, previously sued
herein as DOE No. 1, a
California Corporation, and
DOES 2-20,
Defendant.
No. BC411018
31936 LINDSAY PINKHAM, CSR 3716
Miller & Company Reporters (310) 322-7700 ~ (415) 956-6405 ~ (800) 487-6278
EXHIBIT 4
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QUESTIONS MARKED
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INFORMATION REQUESTED
(None)
Page 457
Thursday, May 3, 2012
I0:40 a.m.
THE VIDEOGRAPHER: Good morning. We are on tht
record. This is the beginning of master No. I in volume
No. 3 in the deposition of Laura Ann Dieckman. My name
is Pierre Dupuy with Habeas Videas.
Ifl could have counsel please identify
themselves for the record.
MR. BLUMBERG: John Blumberg representing
plaintiff.
MR. MANGELS: Robert Mangels representing
defendant Religious Technology Center.
MR. LIEBERMAN: Eric Lieberman representing
defendant CSI.
MR. DAVIDSON: Cliff Davidson representing
defendant CSL
MR. DEIXLER: Bert Deixler, Kendall, Brill &
Klieger, for CSL
MR. BLUMBERG: And let the record reflect that
although she's not here yet, Cindy Smolowitz, also
representing plaintiff.
THE VIDEOGRAPHER: Thank you very much.
This is the beginning of master No. I, Volume
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No. 3. Counsel?
LAURA ANN DIECKMAN,
having been previously duly sworn, was
examined and testified further as follows:
EXAMINATION (Continued)
BY MR. DEIXLER:
Q Good morning, Ms. Dieckman.
A Good morning.
Q You understand your testimony continues to be
under oath and subject to the penalty of perjury?
A Yes.
Q Yesterday we were talking about certain
postings which you had made in July of2008. Do you
recall the general topic that we were discussing
yesterday?
A Yes.
Q And in the course of that, I had showed you
some, and you had indicated that they were a part of a
posting and not the entire posting. Do you remember
that portion of our colloquy yesterday?
A Can you refresh my memory?
Q Perhaps I can by showing you a document which
we'll have marked as Exhibit No. 9, a copy to your
Page 459
counsel, and this was a document that was presented to
us yesterday by your counsel. If you would take a
moment.
(Defendant's Exhibit 9 was sub-
sequently marked for identification.)
Q BY MR. DEIXLER: And I think you will see that
a portion of this is something that we went over
yesterday, and I want to ask you about portions that we
had not gone over. So first let me ask you to identify
your postings here.
Yesterday we determined that your screen name
was "dt2000." Am I remembering correctly?
A Yes.
Q And if you look at this, let me ask you to
start, I guess, at page 15 of 16. There's a post from
dt2000, and I'm trying to associate that with whatever
it is you wrote. So could you identify what it is on
this portion of Exhibit 9, which was written by you in
this chain?
A What do you want me to identify exactly?
Q I can't tell whether you wrote, "Freedom is a
choice. Choose to be yourself," or you wrote, "My
parents have them I will check it out next time." I
can't quite tell --
A I wrote, "My parents have them I will check it
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marked for identification.) 1 A No, because it's two totally separate
Q BY MR. DEIXLER: Take a moment. Perhaps the 2 questions. Being in doubt about Scientology and being
first place to start is the very last page, "Name of 3 in doubt about Sea Org are two totally different things
person filling out life history form," and "Date." 4 to me.
A Yes. 5 Q Okay. What's the difference?
Q Is that your signature? 6 A Being in doubt about being in the Sea Org is
A Yes. 7 meaning I had doubts about wanting to be in that
Q And am I correct that this was a document you 8 organization. Not about Scientology, the technology.
attested to the accuracy of on August 10, 2003? 9 Q Okay. You remained interested in being a
A Yes. 10 Scientologist until the screen that was minimized was
Q To the best of your knowledge in filling out 11 maximized. Correct?
this life history form, were you trying to be accurate? 12 A No. Until my conversation with my mother.
A I don't remember at the time. I don't remember 13 Q Which followed that immediately; correct?
filling it out, so... 14 A No.
Q Can you think of any reason in August of 2003 15 Q It didn't follow that immediately?
why, in filling out a life history form, you would not 16 A No.
have told the truth and attested that you had? 17 Q How much time elapsed between the time you saw
A I don't know. No. 18 your mother's computer with the minimized screen and the
Q Okay. 19 ex-Scientologist board and the conversation with your
MR. BLUMBERG: Well, wait a minute. That's two 20 mother? It didn't happen that day or that night?
answers. You have to pick one. 21 A It happened either later that day or the next
THE WITNESS: I don't recall. 22 day, one of the two.
-r--+-,,,.,,....---,,,-
MR. DEIXLER: Counsel, she's testified. Please 23 Q And then in 25, you say there have been times
don't do that. 24 that you've been in Sea Org when you were in doubt about
MR. BLUMBERG: Yes, she's testified in two w a y ~ 25 being in the Sea Org, and then you go on to give various
Page 5C 1 Page 503
that's ambiguous. I'm trying to clear up the record 1
because she gave two answers. 2
MR. DEIXLER: Don't clarify anything. When 3
your turn comes to examine your client, you can clear up 4

examples that gave rise to your doubts. Correct?
A I gave examples, yes.
Q Okay. And one of the examples you gave is
that:
whatever you want. Let me examine the witness in my ov In 5 "In May 2001, I was in doubt
fumbling way. 6 about being in the Sea Org and again
MR. BLUMBERG: If you're satisfied, I'm 7 wanted to leave and have kids. I lied
satisfied. 8 about being pregnant in order to route
MR. DEIXLER: Perfect. 9 out and pull my husband out with me."
Q Yesterday we had a discussion about whether you 10 Yes?
had doubts about being in Scientology. Do you recall 11 A I wrote that, yes.
that discussion yesterday? -+-.1""".L,.---Q And this was -- it was your desire to give a
A Yes. 13 full and complete answer to the question, No. 25;
14 Q And yesterday you didn't recall that you had 14 correct?
15 doubts about being in Scientology, ifl recall your 15 A I don't recall.
16 testimony. 16 Q Any reason to think you were withholding any
17 A That's correct. 17 information about doubts?
18 Q Let me ask you to take a look at the second 18 A No.
19 page, No. 25, and the question, "Have you ever had 19 Q Okay. In further answer to paragraph 25, on
20 doubts about being in Scientology and/or the Sea Org?" 20 the adjacent page, handwritten, it says:
21 And to which your answer was "Yes." 21 "In September 2003, I briefly for
22 A Yes. 22 about two days went into doubt about
23 Q Does seeing that question and that answer 23 being in the SO. I've since handled
24 refresh your memory that in fact you had doubts during 24 this with ethics and conditions."
25 the time you were a member of Scientology? 25 Did I read that correctly?
Page 502 Page 504
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l Q In 2001 how old were you? l
2 A I was twenty- - how old was I? 22? 22, 2
3 probably. 3
4 Q You were 22 at the time you signed this 4
5 document; correct? 5
6 A Yes. 6
7 Q So I'm focused on the c'ommitment that you're 7
8 making at 22, where you declare a religious commitment 8
9 to spiritual awareness of the Scientology religion. 9
IO A But I don't remember reading this document. IO
11 . Q I understand that. But I'm asking a slightly 11
12 different question. The question is, do you recall that 12
13 during the time you were a member of the Sea Org, you 13
14 were making that kind of commitment to the religion you 14
15 had chosen? 15
16 MR. BLUMBERG: Objection. Overbroad. 16
17 Q BY MR. DEIXLER: You're making a religious 17
18 commitment to spiritual awareness. 18
19 A I don't recall that. 19
20 Q Isn't that why you were participating in the 20
21 Sea Org, to study and act upon the writings of the 21
22 Church of Scientology? 22
23 MR. BLUMBERG: Objection. Misstates prior 23
24 testimony and is overbroad. 24
25 THE WITNESS: I've said why I joined the Sea 25
Page 513
MR. BLUMBERG: Objection. Argumentative.
THE WITNESS: That is not something that is
said to you when you're joining the Sea Org. That's not
what you're signing into, is not to go study. Quite the
contrary.
Q BY MR. DEIXLER: How much time did you spend
studying materials which were the base of Mr. Hubbard's
writing?
MR. BLUMBERG: Objection. Vague as to time.
You're talking about Sea Org or her entire time in
Scientology? That's vague.
Q BY MR. DEIXLER: Answer the question.
MR. BLUMBERG: Because it's such a good
question?
THE WITNESS: What time period? What
exactly -- what time period?
Q BY MR. DEIXLER: Let's start with the Sea Org
service. How much time did you spend during your years
in the Sea Org studying Mr. Hubbard's writings?
A I couldn't' really answer that, because there
were times when I regularly attended study and other
times when I didn't.
Q What's your best estimate?
A I don't have one.
Q Hundreds of hours?
Page 515
I Org. It was to help clear the planet. l MR. BLUMBERG: Objection. Calling for
2 Q BY MR. DEIXLER: And that is a shorthand 2 speculation.
3 reference to say to study the teachings and the writings 3 THE WITNESS: I guess it would be over a
4 and to act in accordance with the technology so that 4 hundred.
5 that goal could be -- so that that could be disseminated ---..,,5--Q.;,.. BY MR. DEIXLER: No. 4 here on Exhibit 18 says:
6 with the goal of clearing the planet. Isn't that what 6 "I understand that all Sea
7 you mean? 7 Organization members, including
8 A No, not really. My concept was different than 8 myself, are members of a religious
9 what you're communicating. My concept was, I was the e 9 order."
IO to clear the planet and do the posts that were assigned IO Did you believe you were a member of a
11 to me. 11 religious order?
12 Q How were you going to clear the planet? 12 A I don't recall this document at all, so I
13 MR. BLUMBERG: I'm going to object to that 13 really cannot answer any question about it, other than
14 question as overbroad and requiring a narrative of 14 it's my signature.
15 extreme length. 15 Q But my question is a little bit different.
16 Q BY MR. DEIXLER: Could you answer the question 16 Whether you remember the document, did you believe that
17 please. 17 you were a member of a religious order when you joined
18 A By doing what was ordered or requested of me in 18 the Sea Org?
19 the Sea Organization. 19 A I believed that Scientology was a religion.
20 Q By a commitment to the study of the materials 20 Q I understand that. The question is, further,
21 in the Sea Org; correct? 21 knowing it was a religion, did you believe that you were
22 A No. 22 part of a religious order as a member of the Sea Org?
23 Q You didn't think you had to study the materials 23 MR. BLUMBERG: That question is vague,
24 in order to carry out the work that you were going to be 24 overbroad, and ambiguous. And compound, and a trick
25 assigned? 25 question.
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THE WITNESS: I don't know. I it and written on it, can you think of any other way
Q
BY MR. DEIXLER: You don't know. 2 that your handwriting got on this document?
A No. 3 A No.
Q
Okay. At the top of the next page -- we should 4
Q
You don't recall having anyone hold a gun to
start at the bottom. It says: 5 your head at the time that you signed any documents for
"I understand that each Sea 6 the Church of Scientology, do you?
Organization member considers himself/ 7 A No. But-
herself a volunteer to create a better 8 MR. BLUMBERG: Wait, you've answered the
world and understands that he/she is 9 question.
not an employee, that is, not entitled 10 MR. DEIXLER: All right, let's go to lunch.
to receive secular benefits such as a II THE VIDEOGRAPHER: We're going off the record.
minimum wage or overtime compensation 12 The time is approximately 11 :57.
[as read]." 13 (Luncheon recess)
Do you see that on the document? 14 THE VIDEOGRAPHER: We are back on the record.
A Yes. 15 The time is approximately I :34.
Q
Directly beneath that it says, "Please 16
Q
BY MR. DEIXLER: Your testimony continues to be
Initial." Whose initials are those? 17 under oath, subject to penalty of perjury. You
A That is my initial. 18 understand that, don't you?
Q
And you don't remember signing this, but you 19 A Yes.
don't deny having done so, do you? 20
Q
Earlier today we talked about whether you had
A That is correct. 21 ever sought a promotion or applied for a different post
Q
And by signing this document and initialing it 22 in connection with the Sea Organization. Do you
where indicated, do you believe it was your intention to 23 remember that conversation we had this morning?
indicate your agreement to the terms? 24 A I remember you asking me if I applied for other
MR. BLUMBERG: Objection. Calls for 25 jobs or posts.
Page 517 Page 519
speculation. She said she doesn't recall the document. I
Q
Let me ask you to take a look at a document
THE WITNESS: I do not recall the document, so 2 which we'll mark as Exhibit No. 19, a multipage
I have no idea what my thought process was. 3 document, and a copy to your lawyer.
Q
BY MR. DEIXLER: When you sign documents which 4 (Defendant's Exhibit 19 was
contain recitals of information, is it your practice by 5 marked for identification.)
signing to indicate agreement with them? 6 THE WITNESS: Yes.
MR. BLUMBERG: Objection. It's overbroad, 7
Q
BY MR. DEIXLER: At the bottom it has your
calls for a legal conclusion, and is vague and ambiguous 8 signature, Laura DeCrescenzo. That was signed by you?
with regard to terms such as recitals. 9 A Yes.
Q BY MR. DEIXLER: Can you answer my question, 10
Q
And it was signed by you on or about July 25,
please? II 1996?
A Can you repeat it? 12 A Yes.
MR. DEIXLER: Why don't we have it read. 13
Q
And what is an "Application For Rank Or Rating
(Record read as follows: 14 Promotion"?
"Q When'you sign documents 15 A In the Sea Org they have, similar to the Navy,
which contain recitals of inforniation, 16 rank and rating, such as petty officer first class,
is it your practice by signing to 17 petty officer second class, petty officer third class,
indicate agreement with them?") 18 chief petty officer, midshipman, and up.
THE WITNESS: I'm not going to say that I 19
Q
And you filled out this application?
agreed to this document, because I don't recall it at 20 A Yes.
all. I don't know the circumstances, I don't know that 21
Q
Is this your handwriting in all the parts?
I read it at the time, I don't know that -- I don't know 22 A No.
anything about it other than that's my signature and 23
Q
Let me find out what's yours. Unless it's
that's my name. And that's my handwriting. 24 clear. Where it says "Applicant/Person being
Q BY MR. DEIXLER: And other than having signed 25 recommended," who's that? Did you write that?
Page 518 Page 520
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Laura Ann DeCrescenzo v. C!h of Scientology International, et al.
l left the Sea Org, or was it better when you were in the 1
2 s ~ o ~ 2
3 A It's been ups and downs, ups and downs. 3
4 Q So ups and downs when you were in the Sea Ori , 4
5 and ups and downs since you left the Sea Org; correct? 5
6 A Yes. 6
7 Q Same question now about having left the faith. 7
8 When you left the faith of Scientology, has your life 8
9 been better? 9
10 MR. BLUMBERG: Object. Vague, ambiguous, IO
11 overbroad, and, like all of the questions for the last 11
12 half hour, time wasting. 12
13 THE WITNESS: Sorry. What was the question 13
14 again? 14
15 MR. DEIXLER: Could you read the question to 15
16 the witness, please? 16
17 (Record read as follows: 17
18 "Q Same question now about 18
19 having left the faith. When you left 19
20 the faith of Scientology, has your 20
21 life been better? ") 21
22 THE WITNESS: Has my life been better? I 22
23 honestly haven't thought about it in terms of a -- I 23
24 don't have an answer to that question, like, categorized 24
25 or -- there are things that have made my life difficult 25
Page 5! 1
l through that whole time period up to present time. Like l
2 I said, there are times that are good, there are times 2
3 that are bad. 3
4 Q BY MR. DEIXLER: What has made for a good tir e 4
5 since you left the Church of Scientology? 5
6 MR. BLUMBERG: I'm not going to allow her to 6
7 answer the question. You're harassing the witness, and 7
8 you've crossed the line. 8
9 MR. DEIXLER: Okay. 9
Q BY MR. DEIXLER: Would you finish answering the
question?
THE WITNESS: Probably during the conversation
with my mom in 2008.
Q BY MR. DEIXLER: So you started to suffer
emotional distress in 2008 when you spoke to your mother
about her views of the Church of Scientology; correct?
A No, that's not what I said. That's when I
started seeing there were things that were emotionally
distressful throughout the time that I had been in the
Sea Org.
Q At the time you were in the Sea Org, you didn't
experience things as emotionally distressful, but when
you spoke to your mother in 2008, you realized that they
must have been emotionally distressful? Is that what
you're saying?
A I'm saying that they were emotionally
distressful. At the time, there were times in the Sea
Org when I thought things were emotionally distressful.
And not in that term. I wasn't thinking the term
"emotionally distressful" at the time.
Q What were you thinking?
A That I was doing something that I didn't want
to be doing, or upset about things that were going on.
Q And can you recall a particular time when you
Page 583
first realized you were upset about something that was
going on, while you were in the Sea Org?
A The biggest one and the one that really is the
whole, you know, the biggest one would be the whole
abortion issue.
Q At the time of your having an abortion, you
were emotionally upset about it; correct?
A Yes.
Q And you were aware of the fact that you were
,.--+---
IO Q After you left the Church of Scientology, did IO emotionally upset at the time of the abortion; correct?
11 you suffer emotional distress? ll A Yes.
12 A Yes. 12 Q And you discussed your fact of being
13 Q When did that start? 13 emotionally upset at the time of the abortion with other
14 A It started - this is kind of hard for me to 14 people; correct?
15 answer, because some of the emotional stress started 15 A Yes.
16 before, that I wasn't looking -- you know what I mean, 16 Q Including your husband; true?
17 like there are things that I wasn't acknowledging as 17 A Yes.
18 emotionally distressful until after. Do you understand 111 MR. DEIXLER: So I'm not sure if we're supposed
19 what I'm saying? 19 to go see the judge or not.
20 Q When did you start acknowledging things as 20 MR. BLUMBERG: The judge has, I think, ordered
21
22
23
24
25
emotionally distressful? 21 us.
A Still an ongoing thing. 22 THE VIDEOGRAPHER: We're going off the record.
Q When did they start? When did you first start 23 The time is approximately 3:16.
to acknowledge things emotionally distressful? 24 (Recess)
(Brief interruption) 25 THE VIDEOGRAPHER: We are back on the record.
I
Page 582 Page 584
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The time is approximately 3:24. I
Q
I should have been more careful. Did you
Q
BY MR. DEIXLER: Now, there came a time in 2001 2 believe that Jesse could remain a Sea Org member and
when you were approached about going into the RPF. 3 married to you if you routed out?
Correct? 4 A No.
A Yes. 5
Q
So your decision to go on to the RPF was a
Q
And who made that approach to you? 6 decision which consisted of, in part, a desire for
A That's a hard question to answer, because there 7 yourself to one day be able to return to the Sea Org, a
were circumstances that I found out beforehand, so 8 desire to remain married to Jesse, and a desire to allow
it's -- I don't know how to answer that question. 9 Jesse to advance his ambition to continue in the Sea
Q Okay. Let's see if we can work on it. Who was 10 Org; is that fair?
the first person who discussed with you your going to 11 A It was the first two. I wasn't thinking or --
the RPF? 12 that wasn't -- him continuing in the Sea Org was not
A I think it was James Parselle, I think. I'm 13 something I was thinking about.
not 100 percent on that. 14
Q
You weren't thinking about Jesse's interests;
Q And where was Mr. Parselle and you at the time 15 correct?
that he raised the topic with you? 16 MR. BLUMBERG: That misstates her testimony.
A I don't remember. I remember one conversation 17 THE WITNESS: That's not what I said.
we had in my room at the Hollywood Inn. I don't 18
Q
BY MR. DEIXLER: You were thinking about
remember if there were other conversations in the org or 19 Jesse's interests.
-- I don't remember. 20 A I wasn't -- that's not something I was thinking
Q But the conversation in the Hollywood Inn room 21 about, period. Like it wasn't- I wasn't thinking, oh,
was one in which Mr. Parselle raised for the first time 22 me going to RPF's going to allow Jesse to continue on
your going to the RPF? 23 post. Those aren't two facts that I was correlating.
A No. It was already on the table. The whole 24
Q
You are aware that Jesse wished to continue in
sequence of events was I read in a document that I was 25 the Sea Org; correct?
Page 585 Page 587
being assigned to the RPF. And then that's when I blew I A Yes.
and went to my grandma's house. And then James Parselle 2 Q You were aware that if you left -- if you
and Jesse convinced me to come back and - yeah. 3 routed out, that unless he divorced you, he couldn't
Q Okay. Jesse, your husband, and James Parselle 4 remain in the Sea Org; correct?
convinced you to come back from your grandmother's 5 A Yes.
house; correct? 6 Q And notwithstanding that knowledge, you don't
A Yes. 7 recall thinking to yourself, "Ifl go to the RPF, it
Q And that you should go into the RPF so that you 8 will allow Jesse to remain in the Sea Org as he
would have a chance of being able to return to become a 9 desires"?
Sea Org member; correct? 10 A No.
A Later, after I was back, that was the 11 Q Okay. So would you say you were recruited by
conversation with James, yes. 12 Mr. Parselle to go to the RPF?
Q And keeping alive the hope of being a Sea Org 13 A I would say I was beaten down to the point that
member was something you were interested in doing; 14 I agreed.
correct? 15 Q Physically?
A Not 100 percent. It was back and forth. 16 A No. Mentally.
Q Back and forth. Ups and downs. 17 Q The representative, Mr. Parselle, and your
A Yes. 18 husband beat you down?
Q But you believed that going on the RPF would 19 A No. Jesse had nothing to do with the
begin to allow Jesse to stay in the Sea Org and pursue 20 conversations.
his ambition. Correct? 21 Q Just Mr. Parselle?
A That was not a subject of discussion. 22 A Between - James and Hansa spoke to me at one
Q Did you believe if you had decided to route 23 point. Who else spoke to me? Katie Johnston, and then
out, that Jesse could remain a Sea Org member? 24 later at the RPF Petal Biggs, Jenny Gambino, Alex Meyer.
A Ifhe did, he would have to divorce me. 25 Q But you had agreed to go to the RPF by the time
Page 58 Page 588
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those folks, the last three, spoke to you; right? I A Yes.
A I hadn't - I had, and then wavered. 2 Q And do you recall who presented the document to
Q You went to the RPF, you wavered, and people 3 you?
spoke to you while you were in the RPF; is that -- 4 A I do not.
A No, I hadn't routed into the RPF yet. 5 Q Do you remember signing the document?
Q But ultimately, you decided to go to the RPF? 6 A No, I don't.
A Yes. 7 Q You don't deny that you signed this document?
Q So let me ask a question. I should have asked 8 A No, I don't.
it before when we were talking about your initial 9 Q "Acknowledgement of RPF Assignment and Election
recruitment. You talked about Shane Whitmore making 10 to Proceed." Right?
some promise to you. Who was Mr. Whitmore accompanied l l A Yes.
by, if anyone, when he made whatever promises he made to 12 Q Do you have a memory ofreceiving such a
you? 13 document, even if you don't recall the exact act of
A He was on a recruitment project with Tobin 14 signing it?
Vannier. 15 A I don't recall the exact circumstances. I
Q Do you remember, is that a man or a woman? 16 couldn't tell you ifl signed this that night or the
A A guy. 17 next morning. I have no idea.
Q Do you remember that Mr. Vannier said anything 18 Q Can you recall where you were when you signed
to you different from Mr. Whitmore said to you on the 19 it?
occasion of your being recruited by him? 20 A No.
A No, I don't remember. 21 Q Can you recall who else was with you when you
Q You told us all you remember about the 22 signed it?
recruitment discussion; correct? 23 A Well, I see the signature of Thomas Welch, but
A Yes. 24 that's about it.
Q And you don't have any notes or anything to 25 Q That's a different question. Do you recall
Page 589 Page 591
refresh your memory about that, as we discussed l that Mr. Welch was with you when you signed it?
yesterday; correct? 2 A I don't recall.
A No. 3 Q As best you can now, you don't recall the fact
Q
So whatever you testified to is your best 4 of your signing it, where you signed it and whether
memory of what was said to you; true? 5 anybody else was with you at the time you signed it.
A It is my best memory. 6 Correct?
Q
Let me ask you now to take a look at 7 A I don't recall.
Exhibit 29, which is a couple-of-page document. 8
Q
If you wanted to refresh your memory about
(Defendant's Exhibit 29 was 9 where you signed it or any other aspect of the
marked for identification.) 10 circumstances of your signing it, to What, if anything,
Q
BY MR. DEIXLER: And we'll start at the end, as 11 would you refer?
we have in the past. 12 A I don't have anything.
A Yes. 13 Q
Okay. Let me ask you to look at
Q
Is that your signature on "Signature of Sea 14 Exhibit No. 30. A copy to your lawyer.
Organization member"? 15 (Defendant's Exhibit 30 was
A Yes. 16 marked for identification.)
Q
Okay. And the copy I have seems to have the 17
Q
BY MR. DEIXLER: Have you had a chance to look
last part of the date cut off. Is that the year 2000 or 18 at Exhibit 30?
2001, as you recall? 19 A Yes.
A 2001. 20
Q
We'll start at the end, as we customarily do.
Q
And this is a document that you signed? 21 Do you see your signature on the bottom?
A That is my signature. 22 A I see that.
Q
And let me ask you to go to the first page. 23
Q
Is this a document that you signed on or about
There is something here in the nature of initials. Are 24 June 27, 2001?
those your initials? 25 A That is the date on the document.
Page 590 Page 592
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that's the person who I would give it to.
I
Q
Did you have some relationship with
2
Ms. Johnston? Friend, supervisor, colleague, someone
3
you had grown up with, anything along those lines? 4
A She was relatively new, but she was an okay
5
friend.
6
Q
And as you wrote in Exhibit 31, in your mind, 7
what was your goal by trying to write it? 8
A I was trying to make myself look as bad as 9
possible so that they wouldn't try and convince me th t JO
I needed to stay in the Sea Org.
II
MR. BLUMBERG: I'm just going to object that
12
these questions and this subject matter is contained on 13
pages 152 and 153 of the prior deposition.
14
MR. DEIXLER: These questions are not so 15
contained.
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MR. BLUMBERG: I'm sorry. We don't need to
17
debate it.
18
MR. DEIXLER: I'm telling you --
19
MR. BLUMBERG: And we don't need to speak,
20
remember? I'll stipulate that everything I say, you 21
deny. That will save time. Okay.
22
MR. DEIXLER: Perfect. And a good thing. 23
Q
So let me understand why "look as bad as 24
possible" so they wouldn't make you stay in the Sea Org.
25
Page 597
to have an abortion." Why did you say that?
A Because I was crazy at the time. I don't know.
I was mentally broken down at this point in time.
Q
When you say "mentally broken down," what do
you mean by that?
A I mean that I did not want to be there anymore.
My grandpa had just died 20 days earlier, and I hadn't
even been allowed to stay long enough to go to his
funeral. And then I got back and got told that I was in
lower conditions because something on my job had been
messed up when I was with my grandpa who was dying. And
I was so upset and so messed up that I was - I was
going nuts. I didn't know how to get -- I didn't want
to spend months on the decks cleaning fucking toilets
and putting - God.
Q
You want to take a break?
A No, I don't. I want to finish this. I was
probably certifiably crazy at the point that I wrote
this.
Q
What do you mean by that?
A I lied about being pregnant. Is that normal?
No. I was so desperate to try and come up with
something to get out and not have to go through so much
shit that that's what I thought would somehow make it
better. But it didn't.
Q So in 2001, in May, you were incredibly
emotionally distressed, weren't you?
A Yes.
Q And you really knew that in 2001; correct?
A I knew that I was very upset.
Page 599
Q And you were very upset because of the policies
of the church?
MR. BLUMBERG: Objection. That's overbroad.
Way overbroad.
THE WITNESS: I was upset because I felt stuck.
I didn't know how to do -- I didn't know how to -- it
was all that I had known my entire life, but I didn't
feel happy, and I didn't want -- I didn't know how to
get -- I didn't know what to do. So this was my unusual
way of coming up with something that I thought would
not -- I don't know what -- I don't know.
Q You were emotionally distressed because of the
policies of the Church of Scientology as they had been
applied to you; is that true?
MR. BLUMBERG: Objection. Misstates her
testimony.
THE WITNESS: I was extremely upset and
J.-' ___ desperate at this point in time.
Q BY MR. DEIXLER: So in May 2001, you were very
upset and desperate. And what was it in particular that
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Laura Ann DeCrescenzo v. c!h of Scientology International, et al. Laura Ann Dieckman - Volume 3
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made you upset and desperate? Was it because your
grandfather had died and you hadn't been given a long
enough leave to be with him? Was that what upset you?
MR. BLUMBERG: Objection. You're harassing the
witness. She gave a very long answer of the things that
upset her.
MR. DEIXLER: Please.
MR. BLUMBERG: Thank you.
THE WI1NESS: Not just that. It was an
accumulation of things over time.
Q BY MR. DEIXLER: What, other than your
grandfather's passing and your inability to spend enough
time with him, was causing you emotional distress in May
of2001?
MR. BLUMBERG: Objection. You're harassing the
witness. She already testified to this.
MR. DEIXLER: Please.
MR. BLUMBERG: I have the right to say what I'm
saying.
MR. DEIXLER: No, you don't.
MR. BLUMBERG: Is "screw you" appropriate?
MR. DEIXLER: No. It's shameful, actually.
MS. SMOLOWITZ: Time to get the judge in now.
THE WITNESS: What question am I answering?
Q BY MR. DEIXLER: You're explaining to me the
Page 601
factors which caused you this emotional distress, other
than the fact of the passing of your grandfather and
your inability to spend time with him. What were the
other factors that caused you this emotional distress in
Mayof2001?
A It's just that throughout - there were - I
had run into trouble on some of the invests that I was
working on and not knowing how to deal with them
properly, I guess.
Q Trouble at work?
A Trouble at work. And then when I was even
trying to go see my grandpa, when he was dying, I wasn't
allowed to go right away, and I had to postpone it, and
it just stirred up every time that it happened through
the entire time. Whenever I needed to see my family, it
was either "no," or it was like jumping through hurdles
to be able to see my family.
Q It was hard to see your family. That was
upsetting you in May of 2001?
A Yes.
Q What else was contributing to your emotional
distress in 2001 in connection with your presence in the
Church of Scientology, other than being unable to see
your family as you wished, unable to see your
grandfather as he was dying, and the problems you were
Page 602
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having at work conducting investigations? What other
emotional distress did you suffer?
MR. BLUMBERG: I'm going to object that these
are questions where the inquiry was made and answers
were given on pages 147, 148, and 149 and 150 and 151
and 152, at least, of the prior testimony. And it is
improper and against the judge's order that you are
inquiring into this.
MR. DEIXLER: Not true.
Q So please, if we could dispense with these
improper objections, allow the witness to complete her
testimony so perhaps we can finish today. We'd like to
do that.
MR. BLUMBERG: If you will finish in five
minutes, I'll let you ask whatever you want, subject to
my procedural objections. Otherwise, I want to see the
judge about this questioning.
MR. DEIXLER: Let's do that. I'm not going to
have you impose arbitrary time limits upon me. And the
judge made it clear you can't do such a thing.
MS. SMOLOWITZ: He doesn't know what you're
doing.
MR. BLUMBERG: You've got a lot of nerve.
MR. DEIXLER: Shame on you.
VIDEOGRAPHER: We're going off the record. The
Page 603
time is approximately 3 :52.
(At 3:52 p.m. the deposition of
LAURA ANN DIECKMAN was adjourned sine
die.)
-oOo-
Page 604
39 (Pages 601to604)
(800) 487-6278

EXHIBIT 5
~ . .
Laura Ann DeCrescenzo v. Church of Scientology Intemattonal, et al. Laura Ann Dieckman - Volume 4
Plaintiff,
versus
Corporation, and DOES 2-20 )
Defendants. i
No. BC411018
TAKEN ON: July 17, 2012
Page 607
Miller & Company Reporters (310) 322-7700 - (415) 956-6405 - (800) 487-6278 '
www.millerreporters.com EXHIBIT 5
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VOLUME 4. DEPOSITION OF LAURA ANN DIECKMAN.
taken on behalf of the Defendants at
302 8th Street, N.W., Suite 200,
Albuquerque, New Mexico, on Tuesday,
July 17, 2012, at 9:04 A.M., before
Althea L. Miller, CSR No. 3353, RPR, CCRR.
APPEARANCES:
For t h ~ Plaintiff:
BLUMBERG LAW CORPORATION
BY: SINDEE SMOLOWITZ, ESQ.
444 West Ocean Boulevard
Suite 1500
Long Beach, California 90802
(562) 437-0403
ssrnolowitz@blumberglaw.corn
For the Defendant Church of Scientology
International:
KENDALL BRILL & KLIEGER
BY: BERT DEIXLER, ESQ.
10100 Santa Monica Boulevard
Suite ins
Los Angeles, California 90067
(310) 556-2700
bdeixler@kbkfirm.com
-and-
RABINOWITZ, BOUDIN, STANDARD,
KRINSKY & LIEBERMAN, LLP
BY: ERIC M. LIEBERMAN, ESQ.
45 Broadway
Suite 1700
New York. New York 10006
(212) 254-1111
Ill
Page 608
APPEARANCES (Continued):
Ill
Ill
For the Defendant Religious Technology
Center:
JEFFER MANGELS BUTLER & MITCHELL, LLP
BY: ROBERT E. MANGELS, ESQ.
1900 Avenue of the Stars
7th Floor
Los Angeles, California 90067
(310) 203-8080
REM@jmbm.com
Also Present: Allan Canwright
Philippe Pedersen
Margo Moir, Videographer
Habeas Videas
Altadena, California
(626) 797-8101
Page 609
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I INDEX
2 WITNESS PAGE
3
LAURA ANN DIECKMAN
4
BY MR. DEIXLER 611
5
6 EXHIBITS
7 DEFENDANTS' PAGE
8 32 Three-page handwritten document 635
entitled "Laura DeCrescenzo
9 Success Story," dated 11 Dec 03
IO 33 Three-page handwritten document 657
dated 12 Oct "Dear Stace"
II
34 Letter to CO CMO DCU from 672
12 Laura, dated I 5 October 1998
with a three-page attachment
13
35 One-page handwritten document 703
14 dated 219198, with the name
"Laura DeCrescenzo" at the top
15
36 One-page document entitle 726
16 "Ethics PAC RPF 10 Mar 2004"
17
18 QUESTIONS MARKED
19 PAGE LINE
20 615 17
21 701 2
22 702 13
23 745 24
24 746 7
25 INFORMATION REQUESTED: None.
Page 610
I Albuquerque, New Mexico
2 Tuesday, July 17, 2012
3 9:04 A.M.
4
5 -oOo-
6
7 THE VIDEOGRAPHER: Good morning. We're
8 here for the continuation of testimony of
9 Laura Ann Dieckman.
10 Today is July 7 --
II THE REPORTER: 17th.
12 THE VIDEOGRAPHER: - 17th -- excuse me --
13 2012. The time is 9:04 A.M.
14 We are on the record.
15 The court reporter will please swear the
16 witness.
17
18 LAURA ANN DIECKMAN,
19 having declared under penalty
20 of perjury to tell the truth, was
21 examined and testified further as follows:
22
23 EXAMINATION (CONTINUED)
24 BY MR. DEIXLER:
25 Q Welcome back, Miss Dieckman.
Page 611
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1 will all go much faster.
2 MS. SMOLOWITZ: Also, the reporter add the
3 following objection. This line of questioning has
4 been covered before, but if Mr. Deixler wants to
5 take the time doing it, we'll let him do it one more
6 time.
7 {The record was read.)
8 THE WITNESS: No.
9 BY MR. DEIXLER:
10 Q Okay. So in a -- in the Exhibit 34, which
11 is before you, you say:
12 "I have now HANDLED," all caps,
13 "the situation with my family for
14 real. I had very good comm cycle
15 with my mom where I confronted with
16 her with what I had observed with her
17 and we came to an agreement that we
18 both were going to grant each other
19 beingness which is what had been
20 really out in our comm line- we
21 were in a games condition which was
22 creating problems obviously."
23 So what were the problems that you were
24 experiencing with your mother at the time that you
25 wrote this?
Page 676
I A I do not recall.
2 Q Any idea at all what kind of problems you
3 and your mother had?
4 A I - I - I don't recall at this time.
5 Q Well, you go on to report that:
6 "I had ... written a KR on her on
7 the disaffection that I had observed
8 with her and my sister (who is
9 routing off staff)."
I 0 Do you see that?
II A Yes.
12 Q Okay. The KR is the knowledge report that
13 you had sent regarding your mother; correct?
14 A That's what it says. I don't recall the
15 KR.
16 Q Okay. Do you recall that you set -- sent a
17 KR about your mother?
18 A I don't recall that. I don't.
19 Q So - so seeing the document which you
20 yourself wrote in October of 1998 doesn't refresh
21 your memory at all about your having reported your
22 mother for ethics violations; correct?
23 A It refreshes my memory in a general sense,
24 but I don't recall the KR or what I wrote in the KR
25 at all.
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1 Q Yeah. I wasn't asking that at the moment.
2 I was asking whether you recall reporting that your
3 mother was, in some fashion, in violation of ethics.
4 Without recalling the specific document,
5 the specific allegations, do you remember that you
6 made such a report?
7 A I - I don't remember.
8 Q Okay. So while you believe this report of
9 October of 1998 is accurate, you don't remember any
10 part of it; correct?
11 A Correct.
12 Q And you don't remember having had any
13 difficulties with your mother at the time; correct?
14 A I don't remember the specifics of it, no.
15 Q Well, do you remember in general that you
16 and your mother didn't get along?
17 A No, I -- I don't think that that's what I
18 was saying.
19 Q Whether you were saying that or not, do you
20 recall that you and your mother didn't get along?
21 A No. That's not what I -- I - I wasn't
22 saying that.
23 Q Okay. That wasn't what I asked.
24 My question is, without reference to what
25 you were saying in Exhibit 34, do you recall that
Page 678
I you and your mother didn't get along?
2 A No.
3 Q Okay. Your memory of your teen years and
4 thereafter are that your mother and you were close?
5 MS. SMOLOWJTZ: Objection. Misstates her
6 testimony.
7 BY MR. DEIXLER:
8 Q Is that true?
9 A I - I don't - sorry. I'm not - you're
10 asking - are you asking me a general question about
11 my relationship with my mom or what are you - what
12 are you -
13 Q I'm asking you the exact question which the
14 court reporter is about to reread, and if you would
15 answer h a ~ please.
17 MS. SMOLOWJTZ: Objection. Lacks
18 foundation. Assumes facts not in evidence. Vague
19 and ambiguous.
20 You can answer if you know the answer.
21 THE WITNESS: No. My memory wasn't that we
22 were close because I was in L.A. and she was in
23 Albuquerque, and I would speak to her perfunctorily
24 most of the time.
25 Ill
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I BY MR. DEIXLER:
2 Q Oh, I see.
3 What does "perfunctorily" mean in that
4 context?
5 A Meaning I would tell her what I felt was
6 appropriate for her to know.
7 Q What do you mean by that?
8 A When I was in the Sea Org, I portrayed most
9 of the time everything is - I don't - I - this is
I 0 getting - I was not close to my mom when I was -
11 when I was in the Sea Org.
12 Q Yeah. And not physically close is my-- is
13 not my focus but emotionally and personally close.
14 A Correct.
15 Q Okay. You were not emotionally and
16 personally close to your mother -- correct? --
17 A Most of the time.
18 Q -- when you were in the Sea Org?
19 A Most of the time.
20 Q And did there come a time when you felt
21 emotionally close to your mother while you were in
22 the Sea Org?
23 A I don't recall a particular time.
24 I know that when I called her in -
25 emotionally close? Probably no. No.
Page 6 0
I Q Do you think your mother made a mistake in
2 encouraging you or supporting you in the decision to
3 join the Sea Org?
4 MS. SMOLOWITZ: Objection. It lacks
5 foundation. Assumes facts not in evidence. And
6 calls for speculation.
7 THE WITNESS: The way I feel now?
8 BY MR. DEIXLER:
9 Q Right here today under oath.
10 A As a mother myself now, I would not- I
11 would not allow my child to do that at the age of
12 12.
13 However, I understand the mental
14 manipulation that went on at that time because I
15 was - I was in it for as long as I was, and I know
16 that I really wanted to join the Sea Org when I was
17 12 years old. I thought that I was doing the best
18 thing I could possibly do, and I was very
19 convincing; so I know I had a big part in it.
20 I also know that Shane Whitmore had a big
21 part in it. I know that - yeah.
22 Q And Shane Whitmore is a recruiter, who - a
23 person who helped recruit you to join the Sea Org?
24 A He is the person that - that recruited me,
25 yes.
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I Q And so you don't blame your parents for
2 allowing you to do what you really wanted to do
3 which was to join the Sea Org; correct?
4 A Correct.
5 Q Okay. You said that in the perfunctory
6 conversations that you had with your mother you most
7 of the time reported positive things about the
8 Sea Org. Is that fair?
9 A Yes.
10 Q And then sometimes did you describe the
11 sort of day-to-day ups and downs to your mother in
12 those calls?
13 A No- most of the time, no.
14 Q Sometimes you did. "Hey, today was a bad
15 day. This happened"?
16 A No.
17 Q You never told her that?
18 A No. Not that I recall.
19 Q Okay. Even when you experienced such a bad
20 time, you didn't reveal it to your mother in phone
21 calls?
22 A Not that I can recall at this time.
23 Q Okay. Is that because you didn't feel
24 emotionally close to your mother and want to share
25 with her the ttibu- -- tribulations you were
Page 682
I suffering at the time?
2 A No. That's because I would get in trouble
3 if I did that.
4 Q If you - so you -- you were fearful that
5 if you reported things that were making you unhappy
6 that you would somehow get into trouble for that;
7 correct?
8 A Yes.
9 Q Okay. But you were experiencing trouble.
10 You just didn't want to tell your mother about it;
11 correct?
12 A At various points. It's not that I just
13 didn't want to tell my mother. I just didn't - I
14 couldn't tell my mother.
15 Q Well, you were on the telephone with your
16 mother, and you were speaking with her; correct?
17 A In my mind, I'll tell you, I could not tell
18 my mother.
19 Q You -- but you were aware -- let me see if
20 we can "elementize" this.
21 You're aware from day-to-day that things
22 about your life in the Sea Org were unpleasant or
23 made you unhappy; correct?
24 A At various points.
25 Q Okay. And you spoke with your mother at
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1 various points, including the points when you were
2 unhappy about something; correct?
3 A Yes.
4 Q Okay. And you decided, for whatever
5 reason, to not tell your mother, as best as you can
6 recall, any of the negative experiences you were
7 having in the Sea Org; is that true?
8 A That I recall.
9 Q Okay. One -- was one part of that not
10 wanting to have your mother know that you were
11 unhappy or dissatisfied? Did that enter your
12 thinking at all?
13 A No.
14 Q Okay. You didn't --you didn't shield your
15 mother from any aspect of your unhappiness to spare
16 her; correct?
17 A No.
18 Q Okay. So during the period that you were
19 experiencing this urthappiness or dissatisfaction
20 while you were on the Sea Org, did you ever discuss
21 it with your grandmother?
22 A The only time that comes to mind is when
23 I - when I blew to her, but I don't remember what I
24 spoke about at that - I don't -
25 Q Okay.
Page 684
I A I don't recall.
2 Q And you blew to her meaning you went up to
3 see her in Portland?
4 A Yes.
5 Q And in going up to see her in Portland, you
6 went to see her because you thought she would be a
7 safe person who would protect you and help you think
8 about what you should next do; correct?
9 A No. I went to her because she was the only
10 one that wasn't a Scientologist that I was at all
11 close to.
12 Q Okay. And you felt close -- emotionally
13 close to your grandmother?
14 A Somewhat.
15 Q Okay. And how did you arrange to get to
16 her?
17 A I - we went over the whole thing before.
18 I took the money that Jesse had to buy the
19 motorcycle, and I got on a plane and went to
20 Portland and showed up at her front door.
21 Q Yeah.
22 My question is -- was -- was intended to be
23 slightly different which is did you give her
24 warning? How did you come about the idea, of all
25 the people in the United States you could have gone
Page 685
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I to spend time with -- how did you select your
2 grandmother, and how did she react upon your
3 arrival?
4 MS. SMOLOWITZ: Objection. Compound.
5 Asked and answered.
6 BY MR. DEIXLER:
7 Q That's what I'm focused on.
8 A I did not give her any warning. I showed
9 up at her door.
10 Q Okay. And -- and what did you explain to
11 her was your reason for showing up unannounced at
12 her home in Portland?
13 A I don't recall. I know - I -1 think I
14 said - I don't know.
15 I know - um, um, um, um.
16 Even then, from what I remember, I tried to
17 keep it off the subject of Scientology and more - I
18 was trying to say I was having difficulty with Jesse
19 and I needed space.
20 I didn't want to - that's how in - I was.
21 I didn't want to say anything about Scientology at
22 that point.
23 Q Was it, in fact, the case that you were
24 having marital problems at the time that you went to
25 see your grandmother?
Page 686
I A No. I don't think so. I mean, we had
2 been - it was right after the whole - the whole
3 false pregnancy period and Jesse had just moved back
4 into the room, like, a week or so before. He was
5 allowed to come back.
6 No. We weren't - it was kind of - 1- I
7 tried to find something that she could relate with
8 rather than say it was about Scientology, from what
9 I remember.
10 Q So what you said to your grandmother was
11 not true?
12 A I - I don't remember. 1- I - I'm just
13 saying, like, generally, I know I tried to make up
14 something that she could understand.
15 Q What you said to your grandmother was not
16 true?
I 7 A I don't remember the exact conversation.
18 Q Well, without remembering the exact
19 conversation, in general, your memory is that what
20 you said to your grandmother about your reason for
21 visiting her unannounced was - was not true;
22 correct?
23 A I don't remember.
24 Q Well, your memory is that you didn't tell
25 your grandmother that you were having serious doubts
Page 687
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I I'm asking you whether any of those are things that
2 you yourself experience, and then I'm going to ask
3 you about them.
4 If it is the case that you don't outwardly
5 manifest upset, you can say that, and we'll move on
6 to another topic.
7 A Most of the time, I try not to outwardly
8 manifest upset.
9 I would say there are times when I have -
10 I have a breakdown and am crying and am up- -
11 upset.
12 Q When was the last time that happened, when
13 you had a breakdown and you were crying because you
14 were upset?
15 A With somebody or by myself or -
16 Q Well, either. Whenever the last time was.
17 A Friday night.
18 Q Okay. And that was when you were looking
19 at documents?
20 A Yes.
21 Q Okay. And you were by yourself?
22 A Yes.
23 Q And you started to cry?
24 A Yes.
25 Q And what caused you to start to cry on
Page 736
I Friday night?
2 A It was more of a feeling of- I don't
3 recall the exact document or the exact thing that
4 set it off. It was just an overall upset about -- I
5 don't - I don't really have words to express other
6 than the whole thing is overwhelming to me, and
7 the - going back into the documents and what not
8 sets me off on it
9 Q I see.
I 0 What - what documents in particular set
11 you off on that?
12 A I - I don't remember what one specific
13 one. It's kind of just the whole subject.
14 Q The whole subject of what?
15 A The forced abortion, the years of my life
16 that I spent there, the confusion or emotions that
17 went on over the years in re- - in regards to the
18 whole subject.
I 9 Q Okay. The emotions regarding the whole
20 subject.
21 What do you mean by that? During the time
22 that you were experiencing these things, what -
23 what -- what were the emotions that you're talking
24 about?
25 A The biggest thing for me is that I don't --
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I I'm - and this goes back to the being closed off
2 where I don't feel like I have anywhere to - anyone
3 to sort through my emotions on the subject, and I
4 tend to close myself off, and I know - I see it
5 happening, and I feel bad about it because, like I
6 mentioned before, I close -
7 Q Do you want to take a moment and collect
8 yourself and then we can continue?
9 MR. DEIXLER: Why don't we go off the
I 0 record for a couple minutes and you can reflect upon
11 this.
12 MS. SMOLOWITZ: We can keep going. Let's
13 finish up.
14 MR. DEIXLER: No. We'll take a break. I'm
15 not going to force the witness to testify when she's
16 this apparently upset.
17 MS. SMOLOWITZ: Well --
18 MR. DEIXLER: So let's go off the record
19 for two minutes.
20 MS. SMOLOWITZ: I think she's going to be
21 upset on this entire line of questioning; so --
22 MR. DEIXLER: Okay. So we're off the
23 record for -- and then we can --
24 MS. SMOLOWITZ: Your choice, Counselor.
25 MR. DEIXLER: Yes, I know it is.
Page 738
I MS. SMOLOWITZ: You're deliberately cutting
2 off this line of questioning --
3 MR. DEIXLER: No. Not at all.
4 MS. SMOLOWITZ: -- showing that she's
5 upset.
6 MR. DEIXLER: The opposite. The opposite
7 ofthat.
8 MS. SMOLOWITZ: Well, I know exactly what
9 you're doing.
10 MR. DEIXLER: I want to make sure that we
11 get her best testimony.
12 MS. SMOLOWITZ: Okay. You are getting her
13 best testimony.
14 MR. DEIXLER: You know, why don't we go off
15 the record and collect yourself.
16 MS. SMOLOWITZ: It is on my objection that
17 the record -- that you're going off the record.
18 MR. DEIXLER: Okay.
20 record at 11 :42.
21 (Off the record.)
23 record. The time is 11 :48.
24 BY MR. DEIXLER:
25 Q So we were discussing before the break the
Page 739
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Laura Ann DeCrescenzo v. C!h of Scientology International, et al.
I emotions that you had experienced at the time of the
2 various events.
3 Do you recall we were talking about how
4 that -- or those emotions came back? Familiar with
5 the topic?
6 A Yeah.
7 Q Okay. So the emotions -- what were the
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8
9
emotions that you were experiencing at the time you 11 :51 :29
were in the Sea Org that get recounted, for example,
10 on Friday night?
11 MS. SMOLOWITZ: Objection. Misstates her
12 testimony. Assumes facts not in evidence. Lacks
13 foundation.
-14 THE WITNESS: I'm not understanding your
I 5 question.
16 BY MR. DEIXLER:
17 Q Okay. You -- your testimony is that on
18 Friday night that, among other things, the emotions
19 of the past came back as you reviewed those
20 documents and thought about things.
21 Remember that?
22 MS. Objection. Misstates her
23 testimony.
24 THE WITNESS: I -- I didn't say the
25 emotions came back. I said that I was emotional and
. '11 :51 :33
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I upset about them.
2 BY MR. DEIXLER:
11:49:54 3 Q About the events that had occurred in the
11 :49:56 4 past?
11 :49:56 5 A About the events.
11:49:57 6 Q Okay. In the past; right? When you were
11 :50:00 7 in the Sea Org as opposed to something that had
11 :50:02 8 happened that Friday?
11 :50:04 9 A Right.
11 :50:04 I 0 Q And so what I'm focused on is what were the
I Q At the time you experienced these events,
2 you had an emotional reaction to them also; correct?
3 A Some.
4 Q Okay. So, for example, what you described
5 as a forced abortion was a decision by you to abort
6 a child so that you could remain in the Sea Org;
7 correct?
A It was a enforced decision. 8
9 Q Okay. Bu.I it was a decision -- that was
I 0 the decision; correct?
11 A The -- after the time spent changing my
12 decision, yes.
13 Q Okay. And that was very emotional for you
14 at the time; correct?
15 A Yes.
16 Q Okay. You had the opportunity, if you
17 wished, to route out of the Sea Org; correct?
18 A It didn't seem that way, but in theory.
19 Q Okay. So in -- for example, in March of
20 2004, you understood that Jess, your then husband,
21 was routing out of the Sea Org; correct?
22 A Yes.
23 Q If it was your desire to remain married to
24 him in 2004, you could have routed out of the
25 Sea Org with him; correct?
Page 742
I A You really have no concept of what that
2 would have been like.
3 Q Uh-huh.
4 A I just can't tell you that right now.
5 Q Yeah.
6 A You have no concept.
7 Q Right.
8 A It's not just you can leave. It's not like
9 that.
10 Q Right.
11: 50:08 11 events that -- that you experienced?
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11 A You make it sound like, "Oh, yeah, I could

11:50:12 12 For example, you talked about the -- what
11:50:14 13 you described as the forced abortion. That was the
11:50: 19 14 decision you made, to remain in the Sea Org rather
11 :50:21 15 than give birth to your child; is that correct?
11:50:32 16 A I stand by what I said earlier.
11 :50:38 17 Q Do you need the question back? Because
11 :50:40 18 you're going to have to answer the question.
11 :50:41 19 A I am answering the question. I'm not going
11 :50:43 20 to say - I'm not rewording what I said earlier.
11:50:46 21 I'm saying that I was upset about the
11 :50:47 22 forced abortion, the issues that had happened in
11 :50:52 23 relation to that. Everything that had gone on
11:50:56 24 during that period. Everything that had gone on.
11 :51 :00 25 I - I look back at it, and it's overwhelming.
Page 741
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12 just leave with him ifl wanted to."
13 No. You know what I would have had to done
14 to leave like that? I would have spent months being
15 handled, and I probably wouldn't have left because
16 that's how it would have happened. That's how it
17 always happened any other time that I wanted to
18 leave.
19 Q Is Jess today a member of the Sea Org?
20 A Jesse.
21 Q Jesse.
22 A And no, he's not.
23 Q Okay. Did he route out?
24 A I have no idea.
25 Q Had you heard that he had left other than
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I about the wage issue - I - I mentioned that
2 previously, but then that - that hadn't really gone
3 anywhere, and I didn't - wasn't particularly going
4 forward with anything at that point.
5 After that - after Hansa saw me, I wasn't
6 particularly thinking about it either until - then
7 I found the document which she had left at my house,
8 and after I posted that, I was contacted by
9 Scott Pilutik and then connected up with Barry.
I 0 Q Before you determined to file the lawsuit,
11 did you discuss the wisdom of that with Daniel?
12 A I definitely told him that I was thinking
13 about doing iL
14 The wisdom of it - whether it was a great
15 idea or a bad idea, I don't recall.
16 Q Have you ever discussed with him the fact
17 that your pursuit of this lawsuit stirs things up in
18 you?
19 A I have a couple of times.
20 Q And when you have spoken to him on the
21 topic of your lawsuit stirring things up in you, has
22 he suggested to you that you should, nevertheless,
23 pursue the lawsuit?
24 A That really hasn't been a matter discussed.
25 Q You, since the filing of the lawsuit,
Page 756
I haven't discussed with him whether you should
2 continue on or not; correct?
3 A Not continuing on hasn't ever been
4 discussed -
5 Q Okay.
6 A - as an option.
7 Q Okay.
8 MR. DEIXLER: All right I'd like to take
9 a short break, and I may be close to being
I 0 completed.
II THE WITNESS: Okay.
13 record. The time is 12:07.
14 (A brief recess was taken.)
16 record. The time is 12:09.
17 MR. DEIXLER: I have no further questions
18 of you at this time.
19 We're going to file motions to compel
20 answers to questions that your lawyers have
21 instructed you to not answer, but for now, I've
22 concluded my examination.
23 THE WITNESS: Okay.
24
25
MR. DEIXLER: All right?
So we should go off the record.
Page 757
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I THE VIDEOGRAPHER: Okay. So this concludes
2 today's deposition of Laura Ann -
3 MS. SMOLOWITZ: What do you want to do
4 about the transcript?
5 MR. DEIXLER: What do you propose?
6 MS. SMOLOWITZ: Did we have a stipulation
7 at the end of the last one?
8 MR. DEIXLER: As I recall at the end of the
9 last one, Judge Sohigian ordered the witness to
I 0 appear for the deposition; so it wasn't concluded.
11 MS. SMOLOWITZ: No. Because we got the
12 transcripts, and we sent them to her; so I think we
13 had a I'm not saying it was concluded but we can
14 makea
15 MR. DEIXLER: What would you propose? What
16 would you like to do?
17 MS. SMOLOWITZ: Well, just that the - the
18 transcript be sent to to my offices, and I'll
19 make sure that the witness and the party reviews it
20 within 30 days of receipt and provide you with any
21 changes, comments, deletions within that time
22 period;
23 That she signs it under penalty of perjury;
24 And that it will be available for all
25 proceedings in this case;
Page 758
I And if it's not, a certified copy can be
2 used.
3 MR. DEIXLER: Okay. And it may be made
4 available upon request?
5 MS. SMOLOWITZ: Correct
6 MR. DEIXLER: Okay. Yes. We'll stipulate
7 to that.
8 THE VIDEOGRAPHER: This concludes Volume 4
9 of Laura Ann Dieckman.
10 We're going off the record at 12:11.
I I MR. DEIXLER: Thank you.
12
13 (The deposition adjourned at 12: 11 P.M.)
14
15
16
17
18
19
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24 Ill
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Page 759
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EXHIBIT 6
f e
Laura Ann DeCrescenzo v. Church of Scientology International, et al. Kelly Forrest
Plaintiff,
versus
Defendants.
)
DEPOSITION OF: KELLY FORREST
No. BC411018
Miller & Company Reporters (310) 322-7700 ~ (415) 956-6405 ~ (800) 487-6278
J
EXHIBIT 6
e
Laura Ann DcCrescenzo v. Church of Scientology International, et al.
8:03:12
8:03:13 2
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appearances.
MS. SMOLOWITZ: Sindee Smolowitz of
Blumberg Law Corporation on behalf of the plaintiff
and the witness.
MR. HINKS: Matthew Hinks, Jeffer Mangels
Butler & Mitchell, on behalf of RTC.
MR. DEIXLER: Bert Deixler, Kendall Brill &
Klieger, on behalfof the Church of Scientology
International.
THE VIDEOGRAPHER: Thank you.
The court reporter will please swear in the
witness.
KELLY FORREST,
having declared under penalty
of perjury to tell the truth, was
examined and testified as follows:
EXAMINATION
BY MR. DEIXLER:
Q Good morning, Miss Forrest.
A Good morning.
8:05:02 I
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Q You understand your testimony today is 8:05:47 23
under oath and subject to the penalty of perjury? 8:05:48 24
A Correct. 8:05:49 25
Page 6
I Q And how did you prepare for your
Kelly Forrest
that document?
A I haven't.
Q Why is that?
MS. SMOLOWITZ: Objection to the extent it
calls for attorney-client privileged communication.
Otherwise, you can respond.
THE WITNESS: Okay. I haven't really read
the -- or I haven't really read this; so I don't
know really what you're asking for.
BY MR. DEIXLER:
Q Okay. Do you have any documents that in
any way pertain to the Church of Scientology?
A No.
Q Okay. And how do you know that?
A Because I don't have anything that pertains
to Scientology.
Q Were you a member of the
Church of Scientology?
A Yes.
Q And for what period of time?
A On and off through - since I was IS.
Q Okay. And I don't mean to pry, but how old
are you now?
A I'm 43.
Q Okay. And when did you stop? You started
Page 8
at 15. When did you stop being a member of the 8:03:54
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2 deposition?
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2 church?
3 A I met with this lawyer on Sunday. 3 A The last time I was a member - I did a
4 Q Indicating Miss Smolowitz? 4 course the last time, I think - I will say 2008.
5 A Yes. 5 Q Okay. About four years ago or when --
6 And she just gave us information on, you 6 excuse me -- you were 39 years old?
7 know, answering correctly to the questions that you 7 A Okay.
8 answer (as spoken), and that's about all I've done. 8 Q And were there times between the age of 15
9 Q Okay. Have you looked at any documents? 9 and the age of 39 when you didn't consider yourself
8:04:26 10
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A I briefly skimmed over, I think, this 8:06:47 10
document. 8:06:49 11
MR. DEIXLER: Indicating Exhibit 59, which 8:06:49 12
is before the witness and a copy to her counsel. 8:06:52 13
(The document referred to was marked as 8:06:56 14
Defendants' Exhibit 59 by the Reporter.) 8:07:08 I 5
THEWITNESS: Yeah. 8:07:10 16
BY MR. DEIXLER: 8:07: 12 17
Q And when did you look at Exhibit 59? 8:07: 15 18
A On Sunday. 8:07:18 19
Q And had you seen Exhibit 59 before Sunday? 8:07: 19 20
A No. 8:07:20 21
Q From the time you first saw Exhibit 59 8:07:27 22
through today, Friday, July 20th, what efforts have 8:07:31 23
you made to locate docu'!lents that are called for in 8:07:36 24
the 16 categories identified in pages 5 through 7 of 8:07:40 25
Page 7
a Scientologist?
A Yes.
Q And can you help me a little bit in
understanding when those time frames were?
A Let's see. 1992.
Q When you were about 23 years old?
A Correct.
Q Okay. So from 15 to 23, you thought you
were - believed you were a Scientologist?
A Correct.
Q What happened after you were 23 and before
you were 39 in terms of your Scientology beliefs?
A I got divorced, I left California, and
moved to Colorado.
Q And when did you resume your involvement
with the Scientology faith?
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Laura Ann DeCrescenzo v. Church of Sc1entology International, et al. Kelly Forrest
8:27:42 A No. No. 8:33:36 Q How old was Forrest, about, at the time of
8:27:44 2 Q Ever mention it to anybody? 8:33:38 2 your conversation?
8:27:46 3 A No. 8:33:39 3 A Hold on. I'm trying to recall.
8:27:47 4 Q I'm the first person you've told? 8:33:49 4 I was married to John; so --
8:27:50 5 A I don't talk about it 8:33:58 5 Q Are you still?
8:27:52 6 Q Well, that's okay. I'm just trying to see 8:33:59 6 A No.
8:27:54 7 if I'm the first person that you revealed that to. 8:34:10 7 Q We're trying to recall the date upon which
8:28:00 8 MS. SMOLOWITZ: He feels honored. 8:34:12 8 you first heard from Toddy --
8:28:02 9 THE WITNESS: Correct. I haven't talked 8:34:15 9 A Correct.
8:28:03 10 about it. 8:34:16 10 Q -- information about your sister.
8:28:03 II BY MR. DEIXLER: 8:34:17 II A Yeah. I was married to John at the time,
8:28:04 12 Q Okay. Have you ever participated in a 8:34:19 12 and so Forrest was probably 17 or 18 at the time.
8:28:10 13 conversation with Laura in which she told you 8:34:40 13 I'm not getting the exact date, but I'm
8:28:14 14 anything about her experiences in the Sea Org? 8:34:42 14 sure I was married to John at the time.
8:29:48 15 A I had breakfast with her before she moved 8:34:45 15 Q Maybe we can do it the other way. During
8:29:51 16 to Yuma. I don't recall when that was; so -- 8:34:47 16 what period of time were you married to John?
8:29:56 17 Q Okay. And that is when her partner got 8:34:49 17 A Sorry. Marry. I think I got together with
8:30:00 18 transferred there for his work? 8:35:33 18 John in '94.
8:30:02 19 A Correct. 8:35:36 19 Q I'm sorry?
8:30:03 20 Q Okay. And it was just the two of you 8:35:36 20 A I think 1-- I got together with John in
8:30:06 21 having breakfast in Albuquerque? 8:35:39 21 '94. I think.
8:35:40 22 Q Okay. That's the front end of your
what do you remember her saying to you 8:35:42 23 marriage, and then the back end of your marriage?
8:30:14 24 and you to her in that conversation? 8:35:44 24 A A year ago.
8:30:27 25 A I asked her about what happened. She told 8:35:47 25 Q You got divorced from him in 2011?
Page 26 Page 28
me that she - she was convinced to have an 8:35:54 A Correct.
2 abortion. 8:35:55 2 Q Okay. So I guess this is not particularly
3 Q Okay. Anything else? 8:35:58 3 helpful in assessing --
4 A That they - the Church of Scientology 8:36:01 4 A I'm sorry.
5 basically interrogated her for two days until she 8:36:02 5 Q -- the particular date.
8:36:04 6 So sometime between 1994 and 20 I I, you
8:36:07 7 heard this from Toddy?
A She told me about the living conditions in 8:36:10 8 A Correct.
9 the RPF and that the only way that she knew to get 8:36:10 9 Q
Okay. But you heard it from Toddy before
IO out of there was to try to commit suicide by 8:36:12 10 you heard it from your sister?
II drinking bleach so that they would offioad her so 8:36:13 11 A Yes.
12 she could finally get out of there. 8:36:14 12
Q And so --
13 Q Anything else? 8:36:15 13 A And I heard the abortion part. I didn't
14 A That's all I recall. 8:36:17 14 hear the bleach part.
15 Q Okay. Before you had this conversation, 8:36:18 15
Q Okay. You heard the abortion part from --
16 had you heard any of these allegations before? 8:36:21 16 from Toddy.

17 A I had a conversation with Toddy. 8:36:22 17 Can you remember how long before

18 Q And how long was this conversation with 8:36:25 18 breakfast -- you know, a year? A day? A week?
19 Toddy before you had breakfast with your sister 8:36:28 19 Five years?

20 Laura? 8:36:39 20 A It was a couple years.

21 A I think it was shortly after Laura had 8:36:40 21
Q
Okay. And do you remember the
"'
22 moved back here after getting out of the Sea Org. 8:36:41 22 circumstances in which Toddy told you about the

23 Q Okay. Shortly after you had moved from 8:36:44 23 abortion?
1t:1;
24 Toddy's house? 8:36:52 24 A Can you word that differently?

8:33:21 25 A Hmm. No. That's not true. Let me think. 8:36:54 25
Q
Probably. If you don't understand it, I

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Laura Ann DeCrescenzo v. Church of Scientology International, et al.
09:35:20
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I A That's the whole reason why I'm divorced
2 today.
3 Q Okay. And what do you mean by that?
4 A Because the Church of Scientology basically
5 told me that I needed to disconnect from my entire
6 family or that he needed to disconnect from his
7 children.
8 Q Bec;ause of Laura's involvement in the
9 lawsuit?
)9:35:49 IO A Correct
)9:35:50 11 Q And thars an aspect of excommunication?
)9:35:53 12 A Correct
)9:35:53 13 Q Okay. And thars one of the religious
)9:35:56 14 tenets of the Church of Scientology?
)9:35:57 15 A Correct
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Q Okay.
MR. DEIXLER: Okay. Let's take a break. I
may be done.
THE VIDEOGRAPHER: We're going off the
record. The time is 9:36.
(A briefrecess was taken.)
THE VIDEOGRAPHER: We are back on the
record. The time is 9:42.
MR. DEIXLER: I have no further questions.
MS. SMOLOWITZ: Same slip?
Page 66
MR. DEIXLER: Sure.
THE VIDEOGRAPHER: This concludes the
deposition of Kelly Forrest.
We're going off the record. The time is
9:42.
{It was stipulated among counsel
that the transcript will be sent to
Ms. Smolowitz's office; that
Ms. Smolowitz will be responsible for
the witness reviewing the transcript
within 30 days ofreceipt and of
providing all counsel with any changes,
comments, deletions within that time
period; that the witness will sign the
transcript under penalty of perjury;
and that the original transcript will be
made available for all proceedings in
this case; and if it is not available, a
certified copy can be used as if it were
the original transcript.)
(The deposition concluded at 9:42 A.M.)
24 Ill
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Kelly Forrest
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I, KELLY FORREST, declare under
penalty of perjury that the foregoing
is true and correct, to the best of
my ability.
Dated this _day of
- - - - - - - - - ~ 2012,
New Mexico.
KELLY FORREST
Page 68
1 I, AL THEA L. MILLER, CSR No. 3353, certify:
2 That the foregoing deposition of
3 KELLY FORREST was taken before me at the time and
4 place therein set forth, at which time the witness
5 declared under penalty of perjury to tell the truth;
6 That the testimony of the witness and al I
7 objections made at the time of the deposition were
8 recorded stenographically by me and were reduced to
9 a computerized transcript under my direction;
10 That this transcript is a true record of
11 the testimony of the witness and of all objections
12 and colloquy made at the time of the deposition.
13 I further certify that I am neither counsel
14 for nor related to any party to said action nor
15 interested in the outcome.
16 The certification of this transcript does
17 not apply to any reproduction of the same by any
18 means unless under the direct control and/or
19 direction of the certifying deposition reporter.
20 IN WITNESS WHEREOF, I have subscribed my
21 name this 30th day ofJuly, 2012.
22
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AL THEA L. MILLER, CSR No. 3353, RPR, CCRR
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EXHIBIT 7
Laura Ann DeCrescenzo v. clch of Scientology International, et al. Stephanie Bauer
Plaintiff,
versus
Defendants.
, ) No. BC411018
DEPOSITION OF: STEPHANIE BAUER
www.millerreporters.com EXHIBIT 7
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Laura Ann DeCrescenzo v. Cl:iurch o Scientology Intemallonal, et . Stephanie Bauer
15:20:41 I there? 15:22:39 I advice based upon your own experience and desires.
15:20:46 2 A I honestly can't remember at this time. 15:22:42 2 Is that fair?
15:20:51 3 Q
Well, would it seem strange to you to have 15:22:43 3 A Yes.
15:20:54 4 fonned the conclusion that your sister was miserable 15:22:43 4
Q
Okay. And you believe you did that;
15:20:59 5 in the Sea Org and yet concluded that "I would like 15:22:45 5 correct?
15:21:04 6 to join it"? 15:22:45 6 A Yes.
15:21:05 7 MS. SMOLOWITZ: Objection. Calls for 15:22:46 7
Q
So whatever your mother recommended to you,
15:21:06 8 speculation. Lacks foundation. Assumes facts not 15:22:48 8 which you don't recall, you are sure that you
15:21:09 9 in evidence. 15:22:51 9 considered it but only considered it as one factor
15:21:09 10 If you have an opinion, you can give it. 15:22:54 10 as you filtered through the other things that you
15:21:12 II THE WITNESS: I honestly felt that she was 15:22:57 II were considering; correct?
15:21:14 12 extremely excited to have a family member deciding 15:22:58 12 A Yes.
15:21:17 13 to join the Sea Org. 15:22:59 13
Q
And the solicitation of your sister Laura
15:21:18 14 BY MR. DEIXLER: 15:23:03 14 was another factor in your decision to consider it;
15:21:18 15
Q
Okay. And did you have any sense, either 15:23:05 15 co!"ect?
15:21:23 16 from the conversations or from your observations, 15:23:06 16 A Yes.
15:21:26 17 that part of the excitement was that she was going 15:23:07 17
Q
How about your dad? Do you remember any
15:21:28 18 to share with her family member the fun and 15:23:12 18 insights or advice your father gave you on the topic
15:21:33 19 interesting things she was doing? 15:23:14 19 of whether you should join the Sea Org?
15:21:35 20 A I honestly can't be certain either way on 15:23:17 20 A No, I don't.
15:21:39 21 that. 15:23:18 21
Q
If your sister had said to you something
15:21:39 22
Q
Okay. Okay. Can you recall, before 15:23:22 22 like "This is horrible. It's the worst thing you
15:21:47 23 deciding whether you would join the Sea Org, 15:23:25 23 could possibly do," do you think that would have
15:21:48 24 speaking to either of your parents on the topic? 15:23:27 24 influenced your decision as to whether you should
15:21:52 25 A Yes. 15:23:30 25 even consider joining the Sea Org?
Page 26 Page 28
15:21:53 I Q Which of your parents? 15:23:32 I A Yes.
15:21:54 2 A Both. 15:23:32 2
Q
Okay. You have no memory of her having
15:21:54 3
Q
Okay. What do you recall saying to your 15:23:34 3 said such a thing; correct?
15:21:59 4 mother and she to you on the topic of your joining 15:23:36 4 A No.
15:22:02 5 the Sea Org? 15:23:38 5
Q
When is the first time you learned that
15:22:03 6 A I can't remember specifically. 15:23:41 6 your sister had had an abortion?
15:22:04 7
Q
What do you recall in substance? 15:23:47 7 A I believe it was 2007, but I can't remember
15:22:05 8 A Just letting her know that I wanted to go 15:23:51 8 exactly.
15:22:07 9 to the Sea Org. 15:23:53 9 Q
Okay. How did it come to your attention?
15:22:08 IO
Q
Okay. Were you soliciting her advice as to 15:23:58 IO A We were having a conversation about
15:22:10 II whether she thought it would be a good thing or a 15:23:59 II something, and it came up.
15:22:12 12 bad thing? 15:24:04 12
Q
Okay. What did she say to you and you say
15:22:13 13 A Most likely. 15:24:08 13 to her?
15:22:15 14
Q
Okay. You don't remember? 15:24:08 14 A I don't remember at this time.
15:22:16 15 A I don't completely know. 15:24:10 15
Q She -- it just sort of popped out?
15:22:17 16
Q
Okay. Do you remember whether your mother 15:24:13 16 A It was just part ofthe conversation.
15:22:19 17 said it was a good idea or a bad idea? 15:24:16 17
Q
Can you remember any other part of the
15:22:21 18 A I don't remember. 15:24:18 1.8 conversation?
15:22:22 19
Q
Okay. Would that have influenced you if 15:24:18 19 A I don't remember any specifics.
15:22:24 20 she thought it was a bad idea? 15:24:20 20
Q
Okay. Do you remember being shocked in
15:22:30 21 A Not necessarily, no. 15:24:22 21 2007 when your sister said --
15:22:31 22
Q
Okay. Would it have influenced you if she 15:24:24 22 A Yes.
15:22:34 23 thought it was a good idea? 15:24:24 23
Q
-- "I had an abortion"?
15:22:36 24 A Not necessarily, no. 15:24:26 24 Do you remember talking to any other family
15:22:36 25
Q Okay. So you would weigh your mother's 15:24:27 25 member about it?
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A No. 15:26:12 1 sister Laura?
Q Didn't talk to your mother about it? 15:26:13 2 A When she came back from the Sea Org.
A No. 15:26:15 3 Q Starting in about 2004?
Q Okay. Did you know whether your mother 15:26:17 4 A Yes.
knew for years that she had had an abortion? 15:26:18 5 Q And has that continued more or less through
A Laura did tell me that at the time. 15:26:23 6 today?
Q Okay. So although in 2007 Laura told you 15:26:23 7 A Yes.
that her mother had known about it for a long time, 15:26:24 8 Q Okay. Today you're doing the sisterly
you didn't follow up with your mother about it? 15:26:27 9 thing of coming to a deposition and having your
A No. 15:26:29 10 sister right -- two seats over, for example;
Q Okay. Nor did you talk to any other 15:26:33 11 correct?
sibling; correct? 15:26:33 12 A I don't know that I'd consider this
A Not that I remember. 15:26:35 13 sisterly.
Q Okay. Can you think of any reason why you 15:26:36 14 Q I understand. I understand.
would not have discussed the topic with your mother? 15:26:37 15 But over the last eight years or so, you
A It was just a conversation between me and 15:26:40 16 would describe your relationship with your sister as
Laura. 15:26:42 17 one of doing things together, being better and
Q. Okay. Where did the conversation occur? 15:26:47 18 better friends; correct?
A I was on the phone with her. 15:26:48 19 A For the most part, yes.
Q Okay. How often were you speaking to Laura 15:26:50 20 Q Yes.
at that time? 15:26:50 21 You've come to know her more closely
A Quite regularly. 15:26:52 22 because you've gotten to spend more time with her;
Q And by "regularly," you mean what? 15:26:55 23 correct?
A Probably every day. 15:26:56 24 A Yes.
Q Okay. And phone calls, personal, face to 15:26:56 25 Q And you like that, don't you?
Page 30 Page 32
face, or both? 15:26:57 1 A Yes.
A Both. 15:26:58 2 Q And you perceive that she likes that also;
Q Okay. And when you would meet up, where 15:27:00 3 correct?
would you do that? 15:27:01 4 A Yes.
A It varied. 15:27:01 5 Q If she didn't, she would say "Get out of
Q What were the possibilities? 15:27:03 6 here. I am not going to meet you in the park and
A My parents' house, my house. 15:27:06 7 take care of your own kids," slam; right?
Q Okay. 15:27:09 8 A I would assume so.
A Her house. 15:27:10 9 Q Okay. And have you found over the years
Q Okay. 15:27: 13 JO that, as you've grown closer, you have talked about
A Going to the movies. 15:27:16 11 more personal, intimate things?
Q Okay. 15:27:19 12 A No.
A Doing sisterly things. 15:27:20 13 Q Well, she told you about her abortion. Do
Q Yes. 15:27:22 14 you regard that as a personal and intimate thing?
Okay. What's a good sisterly thing that 15:27:25 15 A Yes.
you can remember doing with your -- with your Laura? 15:27:26 16 Q Okay. That would be an example of
A Going shopping. 15:27:28 17 something that was a product of your growing
Q Uh-huh. Anything else? 15:27:30 18 relationship; correct?
A Taking our kids to the park. 15:27:31 19 A It was one of the very few times that she
Q Uh-huh. 15:27:33 20 opened up.
A Just normal everyday things. 15:27:34 21 Q Okay. Did you ask her questions that
Q That sisters do? 15:27:36 22 invited her to open up?
A Yes. 15:27:37 23 A I don't remember.
Q Okay. And when did you start doing these 15:27:38 24 Q Okay. Can you recall the first time she
nonnal everyday things that sisters do with your 15:27:42 25 ever told you something negative about her
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experience on the Church of Scientology -- in the 15:29:42 1 Scientologist?
Church of Scientology Sea Org other than her having 15:29:48 2 A I would say probably about somewhere around
had an abortion? 15:29:52 3 2004, 2005.
A I believe it was in 2008, the summer of 15:29:56 4 Q Okay. So by the time your sister returned
2008. 15:30:00 5 from the Sea Org, you didn't think of yourself as a
Q Okay. And in the summer of 2008, where 15:30:04 6 Scientologist anymore; right?
were you at the time your sister first told you 15:30:06 7 A No.
something negative about the Church of Scientology? 15:30:07 8 Q
That's not correct?
A I was at home. 15:30:08 9 A I - I'm sorry. I did not consider myself
Q Okay. And anybody else there? 15:30:10 10 a Scientologist.
A My husband and my children. 15:30:12 II Q Okay. And did you ever convey that belief
Q Okay. And phone or in person? 15:30:14 12 to your -- or lack of belief, I guess, would be
A Phone. 15:30:18 13 fairer -- lack of belief to your sister?
Q Okay. She called you or you called her? 15:30:20 14 A No.
A I called her. 15:30:20 15 Q
Okay. Did you convey it to any other
Q Okay. And how did the conversation come 15:30:22 16 family member?
up? 15:30:23 17 A No.
A I read something that she had wrote about 15:30:25 18 Q You never told any of your siblings, your
her experience. 15:30:29 19 mother, or your father that you were no longer a
Q And where -- how did you know to read 15:30:31 20 Scientologist?
something that she had written about her experience? 15:30:32 21 A No.
A My parents told me about it. 15:30:33 22 Q
Okay. Did you, after 2004, ever attend
Q Okay. Your mother or your father? 15:30:36 23 another Scientology organized event?
A My mother. 15:30:42 24 A Yes.
Q Okay. And what did your mother say? 15:30:44 25
Q
About how many did you attend?
Page 34 Page 36
A She told me that Laura had written her 15:30:46 I A I can't recall at this time.
story down and that it might be interesting for me 15:30:47 2 Q Can you recall any type event you attended?
to read it. 15:31:00 3 A I think I attended a New Year's Eve event.
Q Okay. At the time that your mother made 15:31:06 4 I did a couple of courses. I don't know --
this phone call to you, did you know that your 15:31:09 5 Q Courses? Scientology courses?
mother was no longer a Scientologist? 15:31:10 6 A Yes.
A Yes. 15:31 :I I 7 Q Yes? Do you remember which ones?
Q And had your mother told you that herself? 15:31:13 8 A I do not.
A Yes. 15:31:14 9 Q Okay. Anything else?
Q And how long before the summer of 2008 had 15:31:19 10 A (No audible response.)
your mother shared with you that she was no longer a 15:31:19 II Q So did it--
Scientologist? 15:31:20 12 A Not-- no.
A About a year before that. 15:31:20 13 Q -- strike you as odd that you were taking
Q Okay. So sometime in 2007, the summer of 15:31:24 14 Scientology courses when you no longer believed
2007, your mother told you that she was no longer a 15:31:27 15 yourself to be a Scientologist?
Scientologist? 15:31:29 16 A No.
A Yes. 15:31:30 17 Q Why not?
Q And did she explain the reason why? 15:31:31 18 A Because I knew that if I told my family
A Yes. 15:31:32 19 that I was no longer a Scientologist, there was the
Q What did she say? 15:31:35 20 risk that they wouldn't speak to me.
A I don't recall at this time. 15:31:39 21 Q I see.
Q Okay. As of the summer of 2007, did you 15:31:39 22 And that was based on what?
still consider yourself a Scientologist? 15:31:41 23 A Everything that the church had ever said.
A No. 15:31 :43 24 Q Okay. The church had said that if a member
Q When had you stopped considering yourself a 15:31:48 25 of the church were to leave the church that
Page 35 Page 37
10 (Pages 34 to 37)
(800) 487-6278
EXHIBIT 8

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CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION
CLAIRE HEADLEY,
PLAINTIFF,
vs.
INTERNATIONAL, A CORPORATION
ENTITY, RELIGIOUS TECHNOLOGY
CENTER, A CORPORATE ENTITY
AND DOES 1-20,
DEFENDANTS.
DEPOSITION OF
CLAIRE HEADLEY
Volume 3
ORIGINAL
TRANSCRIPT
CASE No. CV09-3987
DSF (MANx)
Wednesday, November 4, 2009
Reported By:
Judith Schlussel
CSR No. 4307
NDS Job No. 134316
EXHIBIT 8
1
Religious Technology
2
MR. LIEBERMAN: Eric Lieberman for Church
3
of Scientology International.
4
THE VIDEOGRAPHER: If everyone else in the
5
room could please introduce themselves.
10:16:38
6
MR. MCSHANE: Warren Mcshane from Religious
7
Technology Center.
8
MR. CARTWRIGHT: Allan Cartwright from
9
Church of Scientology International.
10
THE VIDEOGRAPHER: If the court reporter
10:16:48

11
could please swear the witness.
12
13
CLAIRE HEADLEY,
14
the witness, having been administered an oath in
15
accordance with CCP Section 2094, testified as
16
follows:
17
18
THE WITNESS: I do.
19
20
EXAMINATION (CONTINUING)

21
BY MR. MARMARO:

22
Q. Ms. Headley, is there any reason we can't
-..,

23
go forward with your best testimony this morning?

24
A. No.

25
Q.
Feeling fine?
10:17:07
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565

1 rights that I had and certainly, I knew that if I
2 did, that I would -- I mean that I was, from the
..
3
documents I had signed, I was -- there was going to
4 be very serious legal consequences against me by the
5 Scientology organization. 03:24:36
6
Q. BY MR. MARMARO: On Page 4 of this
7 document, is that your signature at the bottom half
8 of the page dated May 9th, 2007?
9 A. Yes.
10 Q. And in the top portion of the page, is that 03:24:50
11 your husband's signature?
12 A. Yes.
13 Q. Did the two of you sign it together before
11
14 a notary?
15 A. Yes. 03:25:00
16 Q. You referred earlier in your testimony to
17 abortions that you had and I'd like to explore that
18 area with you now.
19 A. Okay.
20 Q. While you were affiliated with the Church 03:25:25
21 of Scientology International, did you have any

22 abortions?
'

23

A. Yes.
.. '.)
24 Q. How many abortions did you have?
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Q. Let's talk about -- I'd -- strike that.
2
I'd like to -- I'd like to ask you questions about
3
the first abortion. When was that?
4
A. That was sometime in mid-1994.
5 Q.
And you were -- strike that. You were
03:25:53
6
located at the Gold base at that time?
7 A. Yes.
8
Q. That's where you -- strike that. You said
9
earlier, in your testimony this afternoon, you had
10 the procedure done in Hemet?
03:26:05
11 A. No. I said I was in the Riverside Family
12 Planning Clinic.
13
Q. I apologize. You were 19 years old at this
14 time?
15 A. Yes.
03:26:23
16 Q. And you had been married for two years?
17 A. Yes.
18 Q. Were you planning to have a family at this
19 time?
20 A. I wanted to, but I knew that I had no idea 03:26:32
21 how I was ever going to be able to given that I

22
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couldn't leave and staff members at the property are

23 not allowed to have children, and I already knew and
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were interrogated unti 1. r ht>., oCJ n,12<.I t.o have an
2
abortion, and I knew that if I became pregnant, that
3
I would be in some very serious dire straits.
4
Q. I'm going to have to move to strike because
5
it wasn't the question I asked, which was a
03:27:28
..
6
different question. The question was this. At that
7
point in time when you became pregnant in 1994, had
8
you been planning to start a family then?
9
MR. VAN SICKLE: Do you mean basically was
10
this pregnancy a mistake or a planned pregnancy?
03:27:43
11
MR. MARMARO: That will be the next
12 question.
13
MR. VAN SICKLE: The question kind of seems
14 unclear in that regard.
15 Q. BY MR. MARMARO: Was it part of your plan 03:27:52
16
to start a family in 1994 at the time you got
17 pregnant?
18
A. No. I wanted a family. But I was in a
19 position where I knew that I couldn't.
20 Q. Did you have in mind a point in your life, 03:28:07
21 an age in your life when you wanted to start a

22
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family?

23
A. I hadn't thought about that because I was

1;b1 24 in a circumstance where I was not allowed to and
..

25

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03:28:22
736
anyone that got pregnant was immediately and

/
1 forcibly dealt with until they had an abortion.
2 Q.
Was the pregnancy planned or unplanned?
3 A.
It was unplanned. I had not been paid for
4 months at that time and I couldn't afford birth
5
control, and such happened.
03:28:42
6 Q.
Did you discuss with your husband what to
7 do?
8 A. No. I was not allowed to.
9 Q.
Did your husband know you were pregnant in
10 1994?
03:28:57
11 A. Yes.
12 Q.
You had no discussion between the two of
13 you about what to do?
14 A. Such discussion is forbidden and carries
15 consequences.
03:29:05
16 Q. Again, my question was --
17
MR. VAN SICKLE: The answer is no, I think.
18 Q. BY MR. MARMARO: Move to strike. And ask
..
19 the question again .
20
Is it correct that you had no discussion 03:29:13
21 with your husband about what to do concerning the
22 pregnancy; is that correct?
-.
23 A. I think that I had a brief discussion with
24 him, that I had found out that I was pregnant and
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that we would both get in a lot of trouble if I

---- ---------------------------------------------
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1
(i:dr. ; go through with abortion, and not to mention
2
I had no child care or anything -- I mean no
3
medical care or -- I mean there was a number of
4 factors involved, many of the most senior in my
5
mind was that I knew that if I said that I wanted to 03:30:00
6
go through with the pregnancy, that I would be put
7
on heavy manual labor and know that that's extremely
8
dangerous in a pregnancy and so I wouldn't exactly
9
call it a discussion. We talked about the fact
10 that, that that was what I was faced with. 03:30:26
11 Q. Well, what did your husband say?
12 A. He was upset about it and agreed that we
13 had absolutely no other option, and that that's what
14 I recall.
15
Q. Did you have the ability, if you would have 03:30:43
16 the child at that time, to take care of the child

17 consistent with your responsibilities on the base?
18 MR. VAN SICKLE: Objection to the form of

19 the question.
20 Q. BY MR. MARMARO: Let me restate the 03:30:59
21 question. You started to say a moment ago you

..
22

didn't have any child.care. Would you have had

23 child care
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24 A. I restated that as medical.
..
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25 Q. I understand you did. I'm exploring the 03:31:06
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1 child care aspect.
2
A. There is no children allowed on the base.
3 Q.
Let me take it a step at a time. If I ask
4
the questions and you answer it, we move forward, I
5
think as expeditiously as best we can. 03:31:19
6
Did you have the ability to have child care
7 if you would have a baby at that point in time in
8 1994?
9
A. I don't know how to answer that because the
10 circumstances were no one was allowed to have 03:31:37
11 children on the property.
12 Q. Did you have an understanding -- strike
13 that. Did you discuss your decision about what to
14 do with the pregnancy with anybody else on the base
15 other than your husband? 03:31:52
16 A. I don't -- I didn't recall -- well, you say

17 it as a decision. I was talked to by Cynthia
18 Rathbun and Jocelyn Webb and told that I would be
19 put on heavy manual labor if I didn't go through
20 with it, and at that point, I agreed to go to the 03:32:23
21 appointment at the Planned Parenthood in Riverside.

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Q. You say you discussed your pregnancy with

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23 Cynthia Rathbun and Jocelyn Webb?
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24 A. Yes.

25

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1 more than one conversation?
2 A.
I think it was one -- I think it was about
3 two or three conversations.
4 Q.
Do you remember them individually or
5 collectively?
03:32:56
6 A. Collectively. I mean it was a long time
7 ago.
8 Q.
What did they say -- this conversation was
9 about 15 years ago?
10 A.
Yes. 03:33:09
11 Q.
What conversation -- strike that. What was
12 the substance of the conversation they had with you?
13 A. It was that I was pregnant and that if I
14 didn't go through with abortion, that I would be on
15
heavy manual labor and Sec Checking, interrogation, 03:33:24
16 and I had seen two other staff members in that
17 position thereabouts, that were on heavy manual
18 labor while being pregnant and under interrogation,
19 which was Sandy Menkhaus, who was working in the
20
kitchen doing dishes and another person that I saw 03:33:51
21 was Rosi Kamman.
22 Q. When was Sandy Menkhaus pregnant?
23 A. It was early '94, I believe.
24 Q.
What did you observe her doing after she
\Jj2s
was pregnant?
03:34:06
740
1
A. She was ckllnl! manual labor in the
2 kitchen.
3
Q. What do you mean by that?
4 A. Dishwashing.
5 Q . She was washing dishes?
03:34:12
..
6 A. Pots and pans.
7 Q. And doing pots and pans?
8 A. Yes.
9
Q. She was -- strike that. Do you know how
10
far along in her pregnancy that Sandy Menkhaus was 03:34:23

11 washing dishes and doing pots and pans in the
12 kitchen?
13 A. No, I don't know exactly, but I know it was
14 somewhere between five to seven months.
15 Q. Do you consider washing dishes and doing 03:34:42
16 pots and pans heavy manual labor?
17 MR. VAN SICKLE: Object to the form of the
18 question.
19 THE WITNESS: I do when you're talking
20 about pots and pans that feed close to 7 to 800 03:34:53
21 people.

22

Q. BY MR. MARMARO: Did Sandy Menkhaus get an
''-.

23 abortion?

24 A. No.

i;.!)"2
25

03:35:03
741
Q. Did she have the baby?

1 A. I believe so.
2
Q. And after Sandy Menkhaus had a baby, what
3

happened?
4 A. I don't know.
5 Q. So as far as you knew in 1994, Sandy
03:35:10
6
Menkhaus had gotten pregnant, had worked doing pots
7
and pans and dishwashing and had a baby and you
8
don't know what happened after that?
9
10
question. 03:35:26
.Q
11
THE WITNESS: In 1994, I didn't know what
12 happened.
13 Q. BY MR. MARMARO: Did Sandy Menkhaus stay on
14 the base?
15
A. The last time I saw her was in 1994. I had 03:35:33
16
no idea if she had gone through with the pregnancy
17 or not at that time. I knew that she was, they were
18 trying to handle her to go through an abortion up to
19 a point.
20 Q. How do you know that? 03:35:47
21 A. Because I was told that by someone in the
.

22 qualifications division.

23

Q. Who told you that?

24 A. I don't recall.

I

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25
03:35:56
Q. When did you find out that Sandy Menkhaus

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had had a baby?
A. A few weeks ago.
Q . So
in the last few weeks?
A.
In the last month or two.
Q.
Is it the case that for the last 15 years,
6 you thought Sandy Menkhaus had had an abortion?
7 A. I didn't know.
8 Q. In fact, she had a baby?
9 A.
I mean, like I said, I found out one to two
10 months ago.
11 Q.
How did you find out that Sandy Menkhaus
12 had a baby?
13 A. Sinar Parman told me.
14 Q. What about, the other one was Rosi Kamman,
15 did you say?
16 A . Rosi Kamman.
17 Q. What was her situation?
18 A. She was -- had gotten pregnant and was
19 removed from her position and put out at OGH under
20 full-time security watch and both her and her
21 husband were separated and were being, receiving Sec
22
Checking and interrogation to make them change their
23 mind about wanting a baby.
24 Q. And when was this?
A. That was sometime in '94.
03:36:10
03:36:22
03:36:32
03:36:47
03:37:02
743
1
Q. How do you know about this?
2
A. I was told that again by one u i rn-,
3
co-workers in the area that I worked in.
don't
4
remember specifically who told me that at lhe time.
5 Q.
You were told that at the time in 1994?
03:37:17
6 A. Yes.
7
Q. What happened with Rosi Kamman?
8
A. I don't know.
..
9
Q. Did she have her baby?
10 A. I don't know.
03:37:30
11
Q. You don't know one way or the other?
12 A. No.
13
Q. Did she stay on the base after 1994?
14
A. I don't believe so. I didn't know if she
15
ended up in the Rehabilitation Project Force or -- I 03:37:41
16 don't know what happened to her. I wasn't privy to
..
17 that information.
18 Q. All you know is that she left the base and
..
19
you did not know what happened to her after that?
20 MR. VAN SICKLE: Object to the form of the 03:37:53
21
question. All you know is argumentative. She knows

22 . :';')
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23

Q. BY MR. MARMARO: Sandy Menkhaus, I believe

24 you testified that you don't know whether or not she
4
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remained on the base after 1994? 03:38:09

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1
A. The last time I saw her on the base was at
2
that time, was sometime in 1994. And I didn't
3
know -- I said I didn't know what happened to her
4
after that. That's what I said. I didn't say I
5
didn't know if she stayed on the base. I never saw 03:38:30
..
6 her again.
7 Q. You never saw her on the base?
8 A. After that point.
9
Q. You don't know whether she remained on the
10 base or whether she left?
03:38:36
11
A. If she remained on the base, I would have
12 seen her.
13 Q. Your presumption is -- in asking you the
14 question, that was my assumption but I wasn't sure
15 from your answer. Let's move past that. Your 03:38:46
16 belief was that she left the base in 1994?
17 A. Yes.
18 Q. And you do not know where she went?
19 A. No.
20 Q. You do not know the circumstances under 03:38:55
21 which she left?
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A. No.
a)..,..
23
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Q. BY MR. MARMARO: You do not know the


7
1
circumstances :.:r.clpr which Rosi Kamman left?
2 .A.. No.
3
Q. was there a policy in effect in the Sea
4
Organization concerning children and pregnant women
5 in 1994?
03:39:20
..
6
A. There was something written. It's not what
7 was applied at the base that I observed.
8
MR. MARMARO: Let's mark as Exhibit, is it
9
58, a Sea Org Flag Order 3905-1 dated April 3rd,
10 1991.
03:39:40
11
(Deposition Exhibit No. 58 was marked for
12 identification.)
13
Q. BY MR. MARMARO: If you take a moment to
14 review Exhibit 58 and let me know whether you
15
recognize this document as the Sea Org's policy on 03:40:20
16 children promulgated in 1991?

18 question.
19 Q. BY MR. MARMARO: Go ahead.
20 A. As I mentioned, I knew of this. It's not 03:40:33
21 what was applied on base.

:.ED
22 Q. Had you ever -- I'm sorry. Had you ever

lSD
23 reviewed this?
1{!1

24 A. Yes.

'-!io,,.,

25 Q. Had you reviewed this in 1994? 03:40:42

746

4
..
1
Q. In the hierarchy of Scientology, how high
2 is a Class 5 organization?
3
MR. VAN SICKLE: That's a difficult
4 question. I object --
5
MR. MARMARO: Let her answer, not you,
03:45:36
6 Barry.
7
THE WITNESS: I have to show you the whole
8
structure to answer that question.
9
Q. BY MR. MARMARO: Do the best you can. In
10
the hierarchy of Scientology, how high is a Class 5 03:45:45
11 organization?
12 A. It goes up to the level of Class 5.
13 Q. So is it -- strike that. You say when you
14 arrived at the base in 1991, you learned that the
15 policy that is in Exhibit 58 was not the policy that 03:46:00
16 was in force?
17 A. That's right.
18 Q. How did you learn that?
19 A. Because I heard of a number of women being
20 talked into having abortions and I learned that it 03:46:17
21 was a very common practice on the property, and that

..
22

if you said you wanted to leave, even if it was
' ....
23
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1
pregnant, they placed you on an exact calendar by
2
which, during which time they had to convince you to
..
3
go through with abortion while on heavy manual labor
4
and interrogation, so as to not result in the person
5
leaving. 03:46:55
..
6
Q. How did you learn about this?
7
A. I heard of it -- I was working on internal
8
lines and I, I think the medical people every once
'I
9
in a while would talk about taking different people
10
for abortions, that they would talk about who was
03:47:20
11
out at OGH which is the area where people would be
12
detained if they wanted to leave and that's where
13
they would do the manual labor and be under security
14 watch and they would talk about handlings being done
15 on women that had gotten pregnant.
03:47:38
16 Q. When you mention manual labor in your

17 answer, what type of manual labor were you aware of?
18
A. I knew of the work in the galley, in the
19 kitchen, pots and pans. I knew of cleanup and
20 ditches and weeding out at the far end of the 03:48:05
21 property. Those are some of the things that I knew

..
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22 of.

23

Q. Other than working in the kitchen as you
l?.l:i 24 described and when you say working in ditches, what
..

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do you mean by that? Are you referring to gardening 03:48:19
752


1 or --
2
3 question.
4
THE WITNESS: Some of what I saw was
5
digging ditches for sprinkler installation,
03:48:29
..
6
greenhouse work, cleanups. There was a lot of junk
7
at the far end of the property. I sometimes saw
8
people working on that; women.
9
Q. When you say people, do you mean women who
10 were pregnant?
03:48:49
11 A. Yes.
12
Q. Did you know any of these women, did you
13 know who they were?
14 A. Yes.
15 Q. What women did you observe who were doing 03:48:53
16 this labor on the property?
17
A. That I saw personally, I saw Sandy
18
Menkhaus, later on, I saw Laurence Barram.

19 Q. Laurence?
20 A. Laurence Barram.
03:49:13
21 Q. Can you spell the last name?
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22
A. B-A-R-R-A-M.
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23
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A. Let's see. The other ones were ones that I
11

25

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03:49:29
753
didn't see personally, but that I heard of.
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Q. So other women that you didn't see, but you
-
understood they were working in some fashion?
3 A. Or that they were undergoing handlings to
4 go through with abortion.
5 Q. What do you -- do you know the identity of 03:49:41
6 any of those women?
7 A. Yes.
8 Q. What women do you have. in mind?
..
9 A. That went through - - that were made to go
10 through with abortions? 03:49:51
11 Q. Let's get the universe of women. Then we
12 can go back to it. What are the other women that
13 you didn't see performing labor but you said were
14 doing handling of one form or another?
15 A. To go through with abortion. Let's see. 03:50:01
16 It's a very broad period. I mean I know of at least
17 50 to 60 women personally that had abortions.
18 Q. 50 to 60 women on the base had abortions?
19 A. Yes, at least that I know of personally.
20 Q. Tell me as many names as you -- strike 03:50:27
21 that. In what period of time?

22

A. That was over the entire period that I was

23 there. I mean I know there was more than that.

24 That's just ones that I specifically know and can
41
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25 name. I'm sure I could think of more if I put my 03:50:41
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1 mind to it.
2 Q. Did you speak to -- strike that.
..
3 A. I know that -- another person I know that
4 was on heavy manual labor while she was being Sec
- -- --,
5 Checked to through with abortion
!
03:50:54 go was
{

6
7 Q. When was that?
8 A. It was approximately 1992.
..
9 Q. Did you speak to her about her situation?
10 A. No. 03:51:08
11 Q. Did she ever tell you -- strike that. Do
12 you know whether or not she had an abortion?
13 A. I know she did.
14 Q. How is it that you know she had an
15 abortion? 03:51:18
16 A. Because then she resumed a position after
17 she had gone through with it.
18 Q. Did you ever -- strike that. You never
19 spoke to her about the factors that led her to have
20 an abortion? 03:51:28
21 A. It was not something that was ever

22 discussed amongst staff.
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23 Again, going strike. Q. I'm to move to I'm
m
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24 just trying to find out whether you had a
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2
A.
3
..
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i Is it correct that you did
4
not yourself have a conversation with
5
on her decision to have an abortion?
03:51:50
6
A. Yes.
7
Q. Yes, it is true you did not?
8
A. Yes, I did not discuss it with her.
9
Q. Thank you. What other women can you
10
identify who had abortions?
03:52:00
11 A.
12 Q.
13
A.
14 Q.
15
A.
03:52:17
16 Q.
The last name is:
?
17
A. was one of her last names.
18
was another one. She had four or five abortions.
19
Q. Over what period of time?
20
A.
Let's see. Probably over five to ten-year
03:52:34
21 period.
);S

22
Q. Starting when and ending when?

23
A. I don't know when it started. The last one
11bi
1
24
that I heard of was somewhere in the late '90s. I
1
:!::t
25
don't know exactly.
03:52:50
w' 756

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1
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3
4
5
6
7
8
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9
10

11
12
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18
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23
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Q.
>
Were any of Ms. (

prior to 1996?
A.
I don't know that for sure.
! abortions
I believe so.
Q. Did you ever speak to her about her
decision to abort her pregnancy or any of her
pregnancies?
A. Again, it was not something that was
discussed.
Q. Did you ever speak to her on her decision
to abort any of her pregnancies? "Yes" or "no"?
A.
Q.
A.
No.
Who else do you know who had an abortion?
< ..
>
)
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Q. i
A.
Q. When did she have an abortion?
A. The late '90s, early 2000s, thereabouts.
Q. Did you ever speak to her about her
decision to abort her pregnancy?
A. No.
Q. Are there any other women who you know by
name who had abortions?
A.
Q. I missed the last name.
A.
03:53:04
03:53:12
03:53:29
03:53:45
03:54:02
757

1 Q.
'
I b .
an a ortion?
When did Ms.
_ ____,_ _____ j
2 A.
I don't know. She was one of the people
3 that talked to me to convince me to go through with
4 an abortion and she told me in that conversation
5
that she had had an abortion and it was,
03:54:17
..
6
quote/unquote, "no big deal," and that the
7 consequences of not going through with it would be
8 much worse than going through with it.
9 Q. What was --
10 A.
She didn't tell me the date that she had an 03:54:32
11 abortion.
12 Q.
I'm sorry. Did you understand that she had
13 had an abortion prior to the time of this
..
14 conversation?
15 A. Yes.
03:54:40
16 Q.
So it was prior to your abortion?
17 A. Yes.
18 Q.
And what position did she have on the base?
19 A.
She was in the qualifications division in
20
Golden Era Productions.
03:54:52
21 Q.
Did she tell you why she had decided to

J.82:1
......

23 A. She didn't need to. I knew that there was
:;(2:.
24 consequences pretty severe in refusing to do what
... '"-.
\.l:i 25 was asked of you.
03:55:05

758

:e)) Network Deposition Services, Inc. networkdepo.com 866-NET-DEPO

1 Q. She -- strike that. Is it correct that she
r,
... did not tell you why she decided to have an
3 abortion?
4 A. There was no need to discuss it. I knew
5 that there was serious consequences of not doing so. 03:55:15
..
6 Q. Move to strike and ask you a third time.
7 Is it correct that she did not discuss with you the
8 reasons why she decided to abort her pregnancy? Is
9 that a correct statement?
10 A. She didn't discuss it with me. 03:55:27
11 Q. What other women that you know of had
12 abortions?
l
13 A. i
{_ _____ _
\told me that she had had an
'
..
14 abortion.
15 Q.
When have an abortion?
03:55:44
16 A. She didn't tell me.
17 Q. Was this conversation before or after your
18 abortion, your abortions?
19 A. This was around the time of my second
20 abortion. Again, she told me again that it was not 03:55:56
21 a big deal to go through with it and that the

22
@1
consequences of not doing so would be much worse.
'1.....
23

Didr -------
'
-----
Q. tell you what the
___ :
24 consequences would be?
'
'1....._

25 A. She didn't need to. I knew what they were. 03:56:11

r

759
1

1
ldid
j
Q. Did
-- is it true that
2
not tell you what the consequences would be?
3
A. Yes.
4
Q. What other women, to your knowledge, had
5 abortions?
03:56:26
6
A. I can't think of other specific names right
7
now. I can give you a list if you'd like.
8
MR. MARMARO: We'll leave a place in the
9
transcript and if we need to follow up briefly on
10 that subject, can we?
03:57:05
11
MR. VAN SICKLE: Yeah. We'll do that.
12
{INFORMATION REQUESTED:
13
14
15 Q.
BY MR. MARMARO: Did anybody order you to
03:57:11
..
17 A. Yes.
18
Q. Who ordered you to have an abortion?
..
19
A. The first time, was Cynthia Rathbun.
20 Q.
What was Cynthia Rathbun's position?
03:57:21
21
A. She was the medical officer at Golden Era

4

22 Productions.
..
23

Q. And was this in a -- this was in an

24
in-person conversation?

l .....

25 A. Yes.
03:57:37

760


1 Q. How far pregnant were you at the time?
2 A. Possibly six to eight weeks.
3 Q. And what did Cynthia Rathbun tell you?
4 A. Simply that I was pregnant and, because I
5 had done a test, and, and that I believe she made a 03:58:00
6 general statement that if I didn't go through with
7 it, that I would be on heavy manual labor and Sec
8 Checking and yeah.
9 Q. Was you said she was a medical officer.
10 Was she the one who delivered the results of your 03:58:38
11 pregnancy test to you?
12 A. No. She's the one that gave me the -- or I
13 bought a pregnancy test through her and did the
14 test.
15 Q. Was Cynthia Rathbun in a position of 03:58:53
16 authority over you at the base?
17 A. She was the medical person over all the
18 staff, yes.
19 Q. In terms of the lines of authority in the
20 base, did you report to her in any fashion? 03:59:04

. 1;-i
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22 question .

23 THE WITNESS: Not as such.
if;,,1
24 Q. BY MR. MARMARO: Did you who was your
., .... "(,
1.} 25 supervisor at that time in 1994? 03:59:20

761

r----------------------------

1 A.
I believe it was
2
Q. And did you discuss the subject with
..
'
3
;
;
I __:_.----
4
A. Yes. As I mentioned, she told me that the
5
option was, it was much easier -- it was much
03:59:34
...
6
less -- it was much easier to go through with
7
abortion than going through with the extreme
8
consequences that would result if I put up any kind
..
9
of fight about it.
10 Q.
Did you mention to anybody, ask them what
03:59:53
11
the status of Flag order was that said that women
"
12
who had children could be transferred to Class 5
13
organizations?
..
14 A.
No. I knew that that was not the policy
15
that was being operated on at the base so I had no
04:00:10
16
reason to ask about it.
17
Q. Now, at that point in your life, did you
18
want to stay with the Sea Org?
19
20
question. 04:00:29
21
THE WITNESS: I was not in a position to

(Ji 22
leave. I think I said that on and off from '91 at

23
various different times I wanted to and had thought

24
about attempting to leave. Escape was not an easy
'

25
thing to do, particularly with no resources or
04:00:47

762
.H
:!;) Network Deposition Services, Inc. networkdepo.com 866-NET-DEPO
- - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
1 contacts, financial or otherwise, in the outside
2 world, and no easy means of escape without being
..
3 tracked down.
4 Q. BY MR. MARMARO: Did you ever learn how
5 Sandy Menkhaus was able to have her baby and leave? 04:01:00
6 A. No.
7 Q. Getting back to my question which I still
8 don't believe you've answered, in 1994 at the time
9 you were pregnant in terms of what you wanted to do
10 with your life, did you want to remain a Sea Org 04:01:21
11 member?
13 question. It's asked and answered.

14 THE WITNESS: On and off from '91 forward,
15 at various different times I wanted to leave. At 04:01:34
16 that particular time, I was absolutely and
"
17 completely emotionally distraught about the fact
18 that I had ended up pregnant and that now I was
19 essentially, my every move was being watched if I
20 didn't go through with it and I knew that if I 04:01:54
21 didn't go through with it, I would be separated from
~

22
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my husband and I didn't know what consequences that
' ~
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might carry, so I think I considered trying to
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763
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1
Q. BY MR. MARMARO: So you considered escape
2 in 1994?
3
A. Yes.
4
Q. Did you make any plans and think of any
5 contingencies?
04:02:20

6
A. I can't say I -- I couldn't come up with an
7
effective way to do so that would work.
8
Q. When you went to the Riverside Family

9
Planning Clinic to have the abortion, how did you
10 get there?
04:02:37
11
't
A. I was driven there by Mark Treasure.
12
Q. And how far is the Riverside Family
13
Planning Clinic from the Hemet base?
14
A. Approximately a 30-minute drive.
15
Q. And is the Riverside Family Planning Clinic 04:02:50
16
a Scientology affiliated organization in any way,
17 shape or form?
18 A. No.
19
Q. It's a facility open to the general 'public?
20 A. Yes.
04:03:04
21
Q. When you were at the clinic having the

'
22

abortion, did you tell anybody there that you were
.....
23
being forced to have an abortion against your will?

24
A. No. I was coached very carefully on what
,,

25
to answer to their questions .before I went there.
04:03:16

764

..

- ---------------------------------------------------
.....,---
1
Q. roached you and what did they coach you
2 to say?
3
A. Cynthia Rathbun.
4
Q. What did she say?
5 A.
She said that if they asked me any
04:03:25
6
questions, if I
she said specifically if they ask
7
you if you want to talk to a psychologist about your
8
decision, say no; if they ask you if you want to
9
discuss it, say no; and to not get into any
10
discussion with anyone there on the subject.
04:03:48
11
Q. Do you remember this conversation 15 years
12 later?
13
A. Yes, I do. Unfortunately, it was extremely
14
emotionally traumatic at 19 to be going through my
15
absolute worst nightmare come true.
04:04:09
16
Q. Did you believe as you were in the clinic

17
that you were having an abortion against your will?
18
A. Yes.
19
Q. Did you believe you were being held at the
20
Gold base against your will?
04:04:16
21 A. Yes.

4
22

Q. Why didn't you say anything to -- you
'11.:q,
23

didn't say anything to anybody at the Riverside

24
clinic to the effect that you were either having an
\ 1.-'":...

25
abortion against your will or being held against
04:04:27
fil
765
?#

..
..
1 your will?
2
A. I knew it was extremely unsafe to say
3
anything. Mark Treasure was waiting in the waiting
4
room for me. If I did say that, then I would be
5
separated from my husband and cut off from my family 04:04:38
'
6
and that I would be under full-time security watch
7
and on heavy manual labor, and Sec Checking and
8
interrogation.
9
Q. Did you consider just not leaving the
10
facility? 04:04:51

11
A. Leaving what facility?
12
Q. The Riverside Family Planning facility, not
13
leaving, refusing to go back with the individual who
14 brought you there?
15 A.
I thought about screaming for somebody to
04:05:03
16
please help me, but I knew that if I did that, I

17
would never see my husband again.
18
Q. So you thought about screaming in the
19
Riverside -- screaming for help?
20 A. Yes.
04:05:14
21
Q. You thought about doing that as a way to
.

22

escape?
'I<";
23

A. I was desperate to not have to go through
24
with this somehow, some way, and, but I did not have

11.....,

25
any means or options open to me financially or
04:05:25

v
766
"

1 otherwise. If I did scream, they would take me back
2 and I would be under full-time security watch. Mark
..
3 Treasure was waiting in the waiting room for me.
4 Q. When you were in the hospital in Hemet in
5 1999 for your leg, did you consider screaming out 04:05:41
6 for help then?
7 A. No.
8 Q. In 1999, did you consider bringing --
9 strike that. In 1999 when you were in the hospital
10 with your leg, was it your belief that you were 04:05:53
11 being held on the Gold base against your will?
12 A. Yes.
13 Q. Did you consider taking any -- informing

14 anybody at the hospital in Hemet of that fact in
15 1999? 04:06:06
16 A. No. As I mentioned, a good 70 to 90
17 percent of the time there was a staff member there
18 with me, and when you can't walk, your options of

19 escape are highly limited.
20 Q. Well, when you got into the car to drive 04:06:18
21 back to the base in 2004 after the New Years event

""'
22 with your husband, was it your belief that you were
...
:JZ\
23 being held at the Gold base against your will?

24 A. Yes .
"
...,
25 Q. And yet, you and your husband drove back 04:06:31

..
..
..
..
'<.
..
alone in a car to the Go:ci base?
A. Yes. It was an organization car. I think
3 we've discussed that before.
4 Q. Did you consider puliing off to the side of
s the road and going to a bus station? 04:06:43
6 A. Where was I going to go? I had no money,
7 no one to go to. I knew that if I didn't show up
8 the next morning, that instantly, the blow drill
9 would be called and people would be out tracking us
10 down, tracking our phones, everything else. And I 04:06:58
11 didn't know if I talked to my husband about it, what
12 he would say, and if he would just report me and
13 then I would be cut off from him and under full-time
14 security watch.
15 Q. Did you think of just going to a police 04:07:11
16 station and telling the police that there is this
17 facility out in Hemet that is holding me against my
18 will or anything like that in 2004?
19 A. I think I made pretty clear that the
20 mind-set is very much that you absolutely do not 04:07:24
.21 call the authorities when you're there.
22 Q. Let's talk about, did you ask anybody
23 strike that -- in 1994 whether you could have a baby
24 and put it up for adoption?
25 A. Did I ask anybody that? 04:07:54
768
Q. Yes.
A. At the age of 19, I had never even heard of
such a thing.
Q. You had never heard about adoption?
A.
That you could have a baby and put it up
04:08:08
for adoption, no.
Q. You had never heard of adoption at any
point in your life up to 1994?
A. Of having a baby and immediately putting it
up for adoption, no.
04:08:18
Q. Strike that. In 1994, did you know that
there was a concept called adoption where children
are adopted by people who are not their birth
parents?
A. Children adoption, yes. Going through with 04:08:30
a pregnancy and immediately putting a baby up for
adoption, no. I hadn't heard of that. And at the
age of 19, I did not have any idea what my, that
any, that there was anything I can do other than do
exactly what I was being told to do and that if I
04:08:48
didn't, there would be very serious consequences.
Q. Did you know -- up to that point in time in
your life had you known anybody who had been
adopted?
A.
Well, I was adopted at the age of ten.
04:09:01
,
769
' 1 Q. Did you know, other than yourself -- strike
2 that.
3 MR. VAN SICKLE: This is a stretch.
"
4 Q. BY MR. MARMARO: Did you know of any people
5 who had been adopted as children? 04:09:12
6 A. Myself.
7 Q. Strike that. Did you know of anybody who
8 had been adopted as an infant?
9 A. No.
10 Q. Never occurred to you to ask whether you 04:09:20
...
11 could have a baby, have the baby adopted and
12 continue in the Sea Org?
13 MR. VAN SICKLE: Objection. This is just
..
14 silly.
15 THE WITNESS: The only people I had ever 04:09:31
16 seen or heard of wanting to have a baby, I knew had
17 been dealt with with severe consequences, and I was
18 so emotionally distraught about the fact that I was
"
19 pregnant and couldn't have my baby, that the thought
20 of going through with a pregnancy and giving the 04:09:51
21 baby away, are you kidding me. No, I didn't think

...
1":"1 22 about that.
.. ,...
"'
1S
1
23 MR. VAN SICKLE: This is silly. It really
,1,D
24 is absurd.

...
25 THE WITNESS: This was a child of my 04:10:03

770
!,..\.)
41
1
husband. I don't think you understar.d or have
2
any kind of respect for that. We're talking about

3
my child.
4
MR. MARMARO: Do you want to take a break
5
or do you want to keep going?
04:10:18
..
6
THE WITNESS: Is it wrong to show emotion
7
about the subject?
8
MR. VAN SICKLE: We don't really much care.
9
As far as we're concerned, this is absurd. Go
10
ahead. 04:10:28

11
MR. MARMARO: I mean I would appreciate it
12
if you kept your comments to yourself.
13
MR. VAN SICKLE: Well, at some point you
14
cross the line. Right now you're pretty close to
15
crossing it to suggest that she, at 17 -- she hasn't 04:10:35
16
been on television, she doesn't get a paper.
17
MR. MARMARO: Can we spare the argument?
18
You'll have plenty of time to make the argument.
19
MR. VAN SICKLE: I can fill the courtroom
20
up with women who had abortions. I don't think you
04:10:48
21 want that.

22
{f;,i
Q. BY MR. MARMARO: Let's talk about the
k""'
23
second pregnancy. That occurred -- strike that.
m

:1) 24
What were the circumstances -- strike that. You
........

25
were in Clearwater when you discovered you were
04:11:04
(;)
- 771


pregnant in 1996?
A. Yes.
Q. was it a planned or unplanned pregnancy?
A. Unplanned. Again, I hadn't been paid for a
period of two to three months at the time. And I
04:11:16
couldn't afford birth control.
Q. In 1996, was it your plan to have a family
at that point in time?
A. The entire time I always wanted a family
and had thought at various times over the years of
04:11:39
how I could try and escape to have a family.
Certainly, this was not a planned pregnancy at that
time.
Q. And did you discuss your pregnancy with
anybody in 1996?
04:11:52
A. Yes.
Q. Who did you discuss your pregnancy within
1996?
r-
A. Ann Rathbun, Antonella Tisi and\

Q. Is the conversation with\ the
\________ I
04:12:08
,.
:....

conversation you testified to a few moments ago or
.., ......
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!31
is it a different conversation?
,-
..
A. I don't recall.
..
"

-
l(-2:i
772
25 Q.
--rl----'
We'll go through it again then. Other than 04:12:18
J_f,2.
..

1
Ann Rathbun, Anlonella Tisi and
, did you
2
discuss your pregnancy with anybody else?
3
A. No. I asked for authorization to be able
..
4
to call my husband and that was denied.
5 Q.
Who did you ask for authorization to call
04:12:34
6
your husband?
7 A. Ann Rathbun.
8 Q . And what did she say?
..
9 A. She said no.
10 Q. Did you have a phone at that time?
04:12:42
11 A. At that time, no.
12 Q. Other than asking Ann Rathbun -- strike
13
that. Was this a phone call with Ann Rathbun or was
14
she in Clearwater at the time?
15 A.
She was in Clearwater.
04:12:58
16
Q. Was it an in-person meeting?
17 A. Yes.
18
Q. Would you tell me everything that was said
19
between the two of you.
20 A.
She told me that -- well, I had been given
04:13:08
21
a pregnancy test to take by Isabelle Von Neuhaus. I

- 22
-!.
didn't actually know why I was given that test. I
'

23
still don't to this day. I had no concept that I

24
was pregnant at the time. And when the test was
: ..
25
positive, when I took it, Ann told me that I needed
04:13:40

.. ,_.
773

e
1 to go through with the abort. ion and that she had
I 2 arranged for another sta EE member to loan me the
3 money for the procedure: the staff member was Ac dona
4 Medina.
5 Q. Did you have a discussion - - strike that.
04:14:07
6 Is that the entire discussion you had with Ann
7 Rathbun?
8 A. To the best of my knowledge as I remember
9 right now.
10 Q. You mentioned a
conversation with Antonella
04:14:19
11 Tisi?
12" A. Antonella Tisi.
13 Q. Who was Antonella Tisi?
14 A. She was another RTC staff member that was
15 down in Clearwater at that time.
04:14:35
16 Q. What was the conversation?
"
17 A. She was Sec Checking me as to if I had
18 gotten pregnant intentionally to try and leave.
19 Q. What conversation did the two of you have
20 during the Sec Checking?
04:15:02
21 A. She was asking me questions on the E-meter
ri
..
22 about it.
tD
. .,
23 Q. What questions did she ask you?
0
!/) 24 A. Was I -- did I intentionally do that.
1.-,,,
i)
25 Q. She was suggesting that you might get 04:15:14
(Z)
.....
774
~
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..
...,---
1 pregnant so you could leave the Sea Org?
2 A. She was suggesting that I might have tried
3 that as a means of escape.
4 Q. Did she use the word escape?
5 A. I don't recall specifically. 04:15:26
6 Q. Is that your word or her word, as best you
7 can recall?
8 A. I don't recall the exact question.
9 Q. All right. This conversation is 13 years
10 ago? 04:15:36
11 A. Yes.
12 Q. In the Sec Checking, what else did she
13 discuss with you?
14 A. That was the subject matter. I understood
15 that if I said or implied in any way that I had had 04:15:50
16 had an intention to get pregnant that I would be
17 removed from my position and separated from my
18 husband and put on heavy manual labor and further
19 interrogated as to what crimes I had committed that
20 I wanted to leave. 04:16:14
21 Q. You said that you -- you prefaced

,,..
lj:-,IJ

22 everything by saying you understood that. I'm
'
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,.,...
23 trying to find out not what you understood. I'm

24 trying to find out how you reached that
.,
25 understanding and by doing that, I'm trying to ask 04:16:24
i;i:;:'r,

!1"4
775
!l?-J; Network Deposition Services, Inc. networkdepo.com 866-NET-DEPO
the conversation. Let me move to strike that and
ask you what she said to you during that procedure?
MR. VAN SICKLE: If that speech is really
true, you should have just asked her what her
understanding is which you haven't done.
04:16:36
MR. MARMARO: I'm trying to get evidence
which I think comes to conversations. Let me do it
my way which I think is my prerogative.
MR. VAN SICKLE: Within certain boundaries,
yes. I do not object to the question.
04:16:45
Q. BY MR. MARMARO: So going back to the
question, I'm trying to find out all conversations
that you had with Antonella Tisi -- if I'm
mispronouncing the name I apologize. Let me start
again. What did Ms. Tisi say to you during this Sec 04:16:59
Checking on the subject of your pregnancy?
A. That's what I recall.
Q. What is it that you recall?
A. What I just told you.
Q.
You didn't tell me anything in terms of a
04:17:10
conversation.
A. Well, it was interrogation on the E-meter.
Q. What questions did she ask you?
A. She was interrogating me as to whether I
was
had intentionally gotten pregnant as a means
04:17:22
776
-
1
of trying to escape.
2
Q. What did you tell her?
3
A. I said no.
4
Q. And what other questions did she ask you?
5
A.
I don't recall specifically.
04:17:37
6
Q. What's the substance of the other questions
7 she asked you?
8
A. That's one that stuck with me.
.,
9
Q.
Did she mention
strike that. Did the
10
subject of an abortion come up?
04:17:48
..
11
A. I believe that this was after I had already
12
had the abortion.
13
Q. This was after. Other than Ann Rathbun,
14
did you speak to anybody else prior to the abortion
15
at the Clearwater facility concerning the subject of 04:18:03
16
your pregnancy?
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17 A. I think I talked to z _ _ _________ J
18
Q. Was that in person or over the telephone?
19
A. It was in person.

20 Q. What did you say
:and what 04:18:16
21
did she say to you?

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22

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A. She said something along the lines that now

23
that it had come up that I was pregnant, I needed to

24
deal with that or there was going to be
11
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04:18:34

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1 Q. tell you what the
2 consequences would be?
3 A. Not at that time. I already knew what they
4 were.
5
Q. was anything else said in the conversation? 04:18:42
6 A. Not that I recall at this time.
7 Q. Other than what you've told me about, did
8 you have any other conversations with anybody on the
9 subject of your pregnancy prior to the abortion?
10 A. Not that I recall at this time. 04:19:02
11 Q. And other than Sandy Menkhaus, are you
12 aware of any other women who did not have abortions
13 but carried their pregnancy to term and had babies?
14 A. No. Another person that I know, that I
15 thought did abort
f- :- - -- -- - -- -- - - -i
was'; /
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That was 04:19:24
16 the nature of some outrage and reports to David
4
17 Miscavige from a public Scientologist doctor by the
18 name of Megan Shields. She was outraged that
-
19 , had been made to go through with
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20 an abortion when she was six months pregnant which 04:19:48
21 was considered, Megan Shields was bringing up that

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that was absolutely criminal.
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24 A. That was in approximately 2002.
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carry the [Jregnc1nc:r' to term?
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A. She had an abortion.
3
Q. That was in 2002?
4
A. Thereabouts, yes.
5
Q. I'm a little bit confused from your answer. 04:20:16
6
How do you know that?
7
A. Because I saw Megan Shields's report to
8
David Miscavige about the criminality of that
'
9
subject and I had seen another report
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was being dealt with in Ethics on the subject and
04:20:32
,
11
being made to go through with the abortion.
12
Q. Are there women who were pregnant and you
13
don't know one way or the other whether they had an

14
abortion or a baby?
15
A. The only ones that I don't know if they had 04:20:48
16
an abortion, I mean that I didn't know what
17
happened, was Sandy and Rosi. I will give you the
18
list. I don't recall the names right now. But it's
19
at least 50 or 60 people that I know if I put my
20
mind to it, I can name specifically, not provided as 04:21:03
21
a complete list, but as people that I personally
F

22
know were made to have abortions.

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23
Q. Once you do that, we'll see if we need to
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follow up.
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MR. VAN SICKLE: Certainly. The names are
04:21:20
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1 all she's going to know. We're probably going to
2 have another session anyway. If we need to follow
3 up, we'll follow up.
4 MR. MARMARO: Can we go off the record very
5 briefly. 04:21:38
6 MR. VAN SICKLE: Certainly.
7 THE VIDEOGRAPHER: Going off the record.
8 The time is 4:21 P.M.
9 (Recess taken.)
10 THE VIDEOGRAPHER: We are back on the 04:33:38
11 record. The time is 4:33 P.M.
12 MR. MARMARO: We've agreed to conclude for
13 the day and resume the deposition at a mutually
14 agreed upon later time. It will be my effort to try
15 to conclude in a half day at that time. No 04:33:54
16 promises, but that's what I think is achievable.
17 In the meantime, we'll have a stipulation
18 that will apply to this session and yesterday's
19 session that the original transcript will be sent to
20 Mr. Van Sickle; Ms. Headley will review it within 30 04:34:09
21 days of his receipt, notify Mr. Van Sickle who will

"
22 notify counsel of any corrections. It can be signed
'' ....
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23 under penalty of perjury. The court reporter is
24 relieved of her responsibility for maintaining the

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25 transcript. Mr. Van Sickle will retain it pending 04:34:24

-----.L--'
780
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Network Deposition Services, Inc. networkdepo.com 866-NET-D_EPO
.......
1 further proceedings in this case, and if we are not
2 notified of any changes within that 30-day period, a
3 copy can be used for all purposes that an original
4 can be used as if unchanged.
MR. VAN SICKLE: So stipulated.
04:34:41
MR. MARMARO: Thank you. Thank you very
7
much. We'll see you next time.
8
THE VIDEOGRAPHER: This is the end of
9
videotape No. 3 and the end of Volume III in the
10
deposition of Claire Headley. Going off the record, 04:34:51
"
11
the time on the video monitor is 4:34 P.M.
12
(TIME NOTED: 4:34 P.M.)
13
4
14
15
16
17
18
19
20
21

22

23

:Q.:i 24
.. . .....

25

781

1 STATE OF CALIFORNIA
SS:
2 COUNTY OF LOS ANGELES
3
4 I, JUDITH SCHLUSSEL, do hereby certify:
5 That I am a duly qualified Certified Shorthand
6 Reporter, in and for the State of California, holder of
7 certificate number 4307, which is in full force and
8 effect and that I am authorized to administer oaths and
9 affirmations;
10 That the foregoing deposition testimony of the

11 herein named witness was taken before me at the time and
12 place herein set forth;
13 That prior to being examined, the witness named

14 in the foregoing deposition, was duly sworn or affirmed
15 by me, to testify the truth, the whole truth, and
16 nothing but the truth;

17 That the testimony of the witness and all
18 objections made at the time of the examination were
..
19 recorded stenographically by me, and were thereafter
20 transcribed under my direction and supervision;
21 That the foregoing pages contain a full, true

"
22

'""'
and accurate record of the proceedings and testimony to

23
J;&l
the best of my skill and ability;
1J) 24 That prior to the completion of the foregoing
"

t.:,}
25 deposition, review of the transcript was requested.
I'=>
1#1
Jrd<
783
"

1
I further certify that I am not a relative or
2
employee or attorney or counsel of any of the parties,
3
nor am I a relative or employee of such attorney or
4
counsel, nor am I financially interested in the outcome
5
of this action.
6
7
IN WITNESS WHEREOF, I have subscribed my name
8
this 12th day of November
2009.
9
10
11
I
12
;
JUDITH SCHLUSSEL, CSR No. 4307
13
14
15
16
17
18
19
20
21

22
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23
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9

24

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EXHIBIT 9

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CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION
CLAIRE.HEADLEY,
PLAINTIFF,
vs.
INTERNATIONAL, A CORPORATION
ENTITY, RELIGIOUS TECHNOLOGY
CENTER, A CORPORATE ENTITY
AND DOES 1-20,
DEFENDANTS .
DEPOSffiON OF
ORIGINAL
TRANSCRIPT
CASE No. CV09-3987
DSF {MANx)
ASTRA ELIZABETH WOODCRAFT
Volume 1
Reported By:
Linda D. White
CSR No. 12009
Thursday, January 28, 2010
NDS Job No. 135152
EXHIBIT 9.
..
1 state whom you represent.
2
MR. MARMARO: Good morning. I'm Marc Marmara,
10:11:42
3 and I represent the Religious Technology Center.
4
MR. CLEAVER: Sam Cleaver. I represent the
10:11:49
5 Church of Scientology International.
' 6
MR. VAN SICKLE: Barry Van Sickle representing
10:11:53
7 Plaintiff Mark Headley, plaintiff Claire Headley,
8 and for purposes of this deposition, the Witness,
9 Astra Woodcraft.
10
THE VIDEOGRAPHER: Would all others please
10:12:02
4
11 present yourselves.
12
MR. MCSHANE: Warren Mcshane from RTC.
10:12:05
13
ALLEN CARTWRIGHT: Allen Cartwright, Church of
10:12:08
'f
14
Scientology International.
15
THE VIDEOGRAPHER: Please swear in the witness. 10:12:14
16
17 ASTRA ELIZABETH WOODCRAFT,
18 called as a witness on behalf of the Defendants, having
19 been first duly sworn, was examined and testified as
20 follows:

21
..

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22 EXAMINATION
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23 BY MR. MARMARO:
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24 Q. Good morning, Ms. Woodcraft.
10:12:26
..........,.
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25 A. Good morning.
10:12:28
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6


had excuse me . 12:23:41
. . ---.:L_ ------ ---.;
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As far as you remember, .. had made
, __ ._. -
her decision to have an abortion before you spoke to
her?
A. Yes, because ideally, what was supposed to 12:23:49
be the point of that briefing where I was supposed
to go around and spot people who were unhappy about
it, was supposed to be that everyone was in
agreement that, if they did get pregnant, that they
would have an abortion. And there were many women I
had that discussion with who said, "Yes, if I get
pregnant, I've already discussed it with my husband.
I will just have an abortion."
Q. That was the{r choice? 12:24:12
MR. VAN SICKLE: I'll object to the form of the 12:24:13
question. It sure wasn't their choice. That's an
incomplete hypothetical and argumentative.
THE WITNESS: It wasn't their choice. My job 12:24:18
was to interrogate them and to find out who was, you
know, misbehaving, breaking the rules. You were
it was required that that was -- that was what you
would do. So if I asked someone, if their answer
wasn't "Yes, I would have an abortion if I got
pregnant," they were immediately in trouble and in
my office and being interrogated. So no, it wasn't
122
their choice.
BY MR. MARMARO:
Q.
Do you know anybody who made a voluntary
12:24:47
choice to get an abortion?
A. No.
12:24:52
12:24:52
question.
THE WITNESS: No. I only know of women who, in 12:24:53
my opinion, did it because they were pressured to do
it.
BY MR. MARMARO:
Q.
Well, what women do you know who were
pressured to have an abortion?
A.
My sister-in-law, my brother's wife.
Q. Okay. What's her name?
A. j 9
Q.
A.
Q.
A.
Q.
A.
Q.
I'm sorry?
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And when did she have an abortion?
Soon after I had my daughter.
Okay.
She was one of my closest friends.
When did - - so did - -\---would have had
l. - - --
the abortion in 1998?
A. Yes.
12:24:58
12:25:02
12:25:03
12:25:06
12:25:10
12:25:11
12:25:13
12:25:17
12:25:18
12:25:19
12:25:21
12:25:27
123
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1 Q. And you were already out of the Sea Org at 12:25:28
2 that time?
3 A. Yes. But I was still in contact with her 12:25:30
4 and my brother .
5 Q. . So obviously you had no role in convincing 12:25:33
6 her to have an abortion.
7 A. No.
8 Q. And
9 A. But she didn't want to have an abortion.
10 My brother informed us -- in fact, I think my mom
11 informed us first that she was pregnant and that
12 they were trying to handle her to have an abortion,
13 but she didn't want to and she wanted to leave and
14 she wanted my brother to go with him -- with her.
15 And she was very distraught.
16 And then my brother seemed to want to
17 leave too. He started asking my dad if he felt that
18 maybe he could be an architect and started asking
19 questions that would indicate that maybe he wanted
20 to leave.
21
22
23
24
25
And then one day he called up and told us
that he or some -- or she had been
handled, and she'd had an abortion and that she was
staying in the Sea Org. And she stayed for a couple
more months, but she was devastated. And she ended
12:25:36
12:25:37
12:25:37
124

1 up leaving without him a couple months later.
2 But she was -- at this point, she was
1
3 it was within, I think, a very -- she was coming up
4 . to the point where it wouldn't even be legal for her
5 to have an abortion because she didn't want to have
6 one. And it went on for several months until she
7 was convinced to, I think right up until the point
8 where she wouldn't have actually been able to even
9 have one.
10 Q. Did your brother tell you he has convinced 12:26:46
11 his wife to --
12 A. He said she had been handled. 12:26:49
13 Q. Did he say by whom? 12:26:51
14 A. It would probably have been the ethics 12:26:53
15 officer.
16 Q. Did he say by whom? 12:26:56

17 A. No. 12:26:58
18 Q. Did he say that he was trying to convince 12:26:59
19 her not to have a child?
20 A. He may have. 12:27:05

21 Q. And did your mother say that she was 12:27:06
.. .
22 telling her daughter-in-law not to go forward with
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23 the pregnancy?
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24
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12:27:14 A. She didn't want -- I think what happened

25 is my mom realized that my brother was possibly

.,_
125
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considering leaving the Sea Org with Dee and that
the way to handle it was to first handle him. So I
think he was then handled. And then --
Q. By your mother? 12:27:31
A. Well, no, because my mother was in 12:27:31
Florida. So you know, other than phone calls. I
think she would have been giving advice as to his
handlers, as tq how to handle him.
MR. MARMARO: We're just about out of tape.
THE WITNESS: Okay.
MR. MARMARO: Let's go off the record.
THE VIDEOGRAPHER: Okay. This is the end of
Videotape Number 1, Volume I, in the deposition of
Astra Elizabeth Woodcraft. Going off the record.
The time is 12:27 p.m.
(A break was taken)
THE VIDEOGRAPHER: This marks the beginning of
Videotape Number 2, Volume I, in the deposition of
Astra Elizabeth Woodcraft. The time is 1:08 p.m.
BY MR. MARMARO:
Q. Ready to resume?
A. Yes.
Q. Before we broke, we were discussing the
c--:------
situation of your sister-in-law,l
\ _____ -- -- -- -- - - J
A. Yes.
12:27:45
12:27:47
12:27:48
12:27:50
01:09:06
01:09:18
01:09:19
01:09:19
01:09:24
126
1 Q. And I wanted to ask you if you had 01:09:24
2 anything to add to your previous answer.
3 A. You were asking me about my brother and 01:09:29
4 mother's involvement in handling her to stay.
5 Q. I was, and we had the tape run out. And I 01:09:35
6 wanted to make sure you that were finished with your
7 answer if you weren't, and give you opportunity
8 A. Yes. 01:09:41
9 Q. -- to expand on that. 01:09:42
10 A. Okay. So from what I understand, my mom 01:09:44
11 was enlisted to figure out how to handle my brother
12 to handle Dee because that was typically the way it
13 was done. If a woman got pregnant or wanted to have
14 a baby, the way they convinced her to have an
15 abortion would be to kind of pit husband and wife
16 against each either, handle the husband to then
,
17 handle the wife. Because it would be much more
18 likely that she would not want to leave.by herself

19 and have a baby by herself if her husband wasn't on
20 board.
21
.
So from what I understand, my mom gave
..

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22
advice on how to handle my brother. My brother was
'
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handled to want to stay. He /he wasn't
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24 going to leave, you know, she would have to leave
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127

"

1 going to leave with her. And then convinced her to
2 have the abortion.
..
3 But the people directly handling my
4 brother and her would have been their ethics
5 officer.
6 Q. Let me ask you: How did you -- you just 01:10:38
7 told me what you understand to be the case.
8 That's not based on firsthand knowledge,
9 is it?
10 A. For them specifically, partly 01:10:44
11 conversations with my brother and my mom and Dee.
12 And partly on just knowing how -- how they handle
13 people.
14 Q. The modus operandi? 01:11:00
15 A. Yes. 01:11:02
16 Q. In terms of the way in which people were 01:11:03
17 handled, generally a spouse would talk to his wife?
18 A. Well, they would -- if they -- they don't 01:11:13
..
19 consider -- family isn't really considered family.
20 Like that instance where I talked about the mom who

21 wasn't allowed to and go see her daughter who was
..
22 saying she was suicidal. So it wouldn't be
..

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23 considered the husband's job to the handle the wife.
.
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24 What they would do is the ethics officer would

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25 enlist the husband and use the husband as a tool to
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128


1 handle the wife.
2 Q. And then, according to your experience, a 01:11:37
..
3 husband would go to his wife and say, "I'm not going
4 to leave if you leave and have a baby"?
5 A. Yes. 01:11:46
6 Q. And therefore, the idea would be, if the 01:11:46
7 woman wanted to stay with her husband, she would
8 have an abortion?
9 MR. VAN SICKLE: I want to object to the form 01:11:54
10 of the question. That misstates the evidence.
11 If she didn't have any money, if she
12 didn't have another source. Omitted a few things.
13 The question is not fair.
14 MR. MARMARO: You made your objection. 01:12:05
15 BY MR. MARMARO:
16 Q. Go ahead. 01:12:07
t
17 A. The idea being that it's another layer of 01:12:08
18 pressure to put on the woman who's already, you
19 know, maybe in a more emotional state, she's
20 pregnant, she's not quite sure of her future. So if
.. '
21

she doesn't have her husband to support her, she

......
22 might be even less likely to be willing to go out

23 into the world with maybe no education, no job

24
11

training, no money and no support.

25 Also, what they would do is they would --
-

129

i

1 they would -- this happened to several of my
2 friends. They would route the woman out. She would
3 leave more quickly, but they'd keep the husband,
4 sometimes up until almost the point where the baby
5 was born, in an attempt to split them up and get. one
6 of them to stay.
7 Q. And the women in those cases left and had 01:12:50
8 the baby?
9 A. Yes. 01:12:52
10 Q. Now, in terms of the conversations you 01:12:53
..
11 had -- let me -- let me -- excuse me. Still
12 discussing your sister-in-law's situation.
13 A. Yes. 01:13:03
14 Q. What conversations -- strike that. 01:13:04
15 All of this happened after you yourself
16 left the Sea Org, correct?

17 A. This happened after, yes. 01:13:12
18 Q. So in terms of the conversations you had 01:13:13
19 with
-1
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how many conversations did you have with
20 her about her decision to have an abortion?
21

A. Probably two. 01:13:23
..
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22 Q. And were they both before the abortion? 01:13:24
''.r.r

23 A. No. I didn't speak to her before -- 01:13:26
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24 Q. Okay. 01:13:28
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25 A. -- the abortion. 01:13:28
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130
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1

1 Q. These were all after the abortion? 01:13:30
2 A. Yes, because she was -- when she was 01:13:31
..
3 pregnant, she was under security watch and wouldn't
4 have been allowed to speak to anybody. So she
5 wasn't allowed to have contact with me.
Q. And what did you -- were these in-person 01:13:39
7 conversations or telephone conversations?
8 A. One in person, I think, and one telephone. 01:13:44
9 Q. Okay. Let's talk about the in-person 01:13:47
10 conversation.
t
11 Where did that take place?
12 A. From what I recall, they came over to my 01:13:54
13 dad's house. They would come over every few weeks,
14 maybe once -- well, no, not that often. But they'd
15 come over a couple times since I'd left, to see my
16 daughter. And this was before I spoke out about
17 Scientology and before I had stated anything to
18 anyone in Scientology that I didn't agree with

19 Scientology. I had left the Sea Org, but I was not
20 considered an ex-Scientologist at the time.
21
. '

So my brother would contact me to ask me
11
igi 22 about paying my freeloader bill. And sometimes he
:::;

23 would come by sometimes he'd come by to borrow
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24 money from my dad. Sometimes they'd try and send

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131


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EXHIBIT 10
:.
Filed 6/24/11 DeCrescenzo v. Church of Scientology CA2/3
NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS
a 1 mia Rules of Court, rule 8.111 &(a), prohibits courts and parties from citing or relying on opinions not ce
publlcatlon or ordered publlshed, except as specified by rule 8.1115{a). This opinion fias not been certified for
publication or ordered published for purposes of rule 8.1115(a).
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
SECOND APPELLATE DISTRICT
Plaintiff and Appellant,
v.
INTERNATIONAL et al.,
DMSION THREE
B224409
(Los Angeles County
Super. Ct. No. BC411018)
Defendants and Respondents.
APPEAL from a judgment of the Superior Court of Los Angeles County,
Ronald M. Sohigian, Judge. Reversed with directions.
Metzger Law Group, Raphael Metzger and Kathryn Darnell for Plaintiff and .
Appellant.
Proskauer Rose, Bert H. Deixler, Harold M. Brody, G. Samuel Cleaver;
Jeffer Mangels Butler & Mitchell, Robert Mangels, Matthew D. Hinks; Rabinowitz,
or
Boudin, Standard, Krinsky & Lieberman, Eric M. Lieberman and David B. Goldstein
:'.q) for Defendants and Respondents.
EXHIBIT 1 o
Laura Ann DeCrescenzo appeals a judgment dismissing her complaint against
Church of Scientology International (Scientology) and Religious Technology Center
(collectively, defendants) after the sustaining of demurrers without leave to amend
based on the statutes of limitations. Plaintiff contends she has adequately pled
a combination of delayed discovery of her causes of action and a basis for equitable
estoppel precluding defendants from asserting a statute of limitations defense. Our
review of this record compels the conclusion that plaintiff has adequately alleged that
(1) she was unable to comprehend the wrongfulness of the defendants' conduct for
a period of time and that her causes of action did not accrue until she did so and
(2) even after her delayed discovery of her causes of action, the defendants' threats and
intimidation caused her to delay filing her complaint. In addition, we reject defendants'
contention that plaintiff is collaterally estopped from prosecuting her action by a federal
court judgment that equitable estoppel was inapplicable because the facts alleged in
plaintiff's prior complaint were insufficient to demonstrate reasonable reliance on
defendants' representations. We hold that her allegations of additional facts in the
. present complaint establish a basis for reasonable reliance and such new allegations are
not precluded by the federal judgment We therefore will reverse the judgment with
directions.
FACTUAL AND PROCEDURAL BACKGROUND
Plaintiff filed a complaint against Scientology in April 2009 alleging that she
began working for that organization at the age of nine, became effectively a full-time
employee at the age of ten, and later left her home and family in another state to work
2
e
for Scientology in California. She alleged that she married a co-worker at the age of
sixteen, became pregnant, and that Scientology forced her to have an abortion at the age
of seventeen. She also alleged that during the time she was employed by Scientology,
from 1991to2004, she was paid less than the minimum wage and worked under other
illegal conditions.
Plaintiff further alleged that (1) Scientology severely restricted her personal
freedom and applied repressive measures to enforce her loyalty to the organization;
(2) she was allowed to leave her employment in 2004, at the age of 25, only after she
had attempted suicide; (3) she had little formal education at that time, was
unsophisticated, and had been isolated from mainstream society and culture; ( 4) she was
subjected to a coercive exit interview and required to sign documents purportedly
exculpating Scientology, and that the documents were illegal and unenforceable; (5) she
was not given a copy of the documents that she signed and ( 6) Scientology falsely
represented to her in the exit interview that she had no claims and no recourse against
Scientology and others and that she owed Scientology approximately $120,000 for her
job training.
Plaintiffs original complaint against Scientology pled six causes of action
denominated as: (1) rescission; (2) unpaid wages; (3) discrimination and invasion of
privacy; (4) human trafficking; (5) intentional inflicting of emotional distress; and
( 6) obstruction of justice. She filed a first amended complaint in May 2009 modifying
some of her counts and adding a seventh count for fraud and deceit. Scientology
removed the case to the United States District Court for the Central District of
3

California and then moved to dismiss based on the statute of limitations and other
grounds. Plaintiff opposed the motion.
The federal court concluded that the only federal claim in the first amended
complaint was the fourth count for human trafficking and forced labor under
18 United States Code sections 1589 and 1595. The court stated that the cause of action
had accrued no later than 2004 when plaintiff allegedly became free from Scientology's
control, was able to learn of her rights, and had full knowledge of the factual allegations
giving rise to her claim. The court concluded that the applicable limitations period
under federal law was four years.
The federal court rejected plaintiff's argument that Scientology was equitably
es topped from asserting the statute of limitations. The court first addressed plaintiffs
argument that Scientology had concealed the facts giving rise to her claim. It stated that
despite the allegations of coercion and deceit, plaintiff had failed to allege that the facts
giving rising to her claim were concealed from her and, to the contrary, affrrmatively
alleged that she was aware of her mistreatment. It then addressed plaintiffs argument
that Scientology had misled her as to her legal rights through coercion and intimidation.
The court concluded that the factual allegations in the complaint compelled the
conclusion that plaintiff was aware of the alleged wrongdoing and had made
a calculated decision to leave Scientology, and that her continued reliance on the alleged
representations as to her legal rights and obligations therefore was unreasonable as
a matter of law. The court also rejected plaintiff's equitable tolling argument. It
';::. therefore granted the motion to dismiss the fourth count with prejudice and remanded
4
- the remaining state law claims to the superior court. The federal court entered
a judgment accordingly in November 2009. Plaintiff did not appeal the federal
judgment.
Following remand from the federal court, Scientology demurred to the first
amended complaint based on the statutes of limitations and failure to allege facts
sufficient to constitute a cause of action. Plaintiff filed opposition. The trial court
below concluded that plaintiff had failed to allege sufficient facts to avoid the statute of
limitations bar for the period after 2004 and sustained the demurrer with leave to
amend.
Plaintiff filed a second amended complaint in February 2010 which added
Religious Technology Center as a defendant. She alleged counts for (1) forced abortion
in violation of her right to privacy under the California Constitution; (2) forced abortion
in violation of her right to privacy under California common law; (3) deprivation of
liberty in violation of her rights wider the California Constitution; (4) false
imprisonment; (5) intentional infliction of emotional distress; (6) wage and hour
violations; and (7) unfair business practices. She restated the factual allegations in her
prior complaint and then alleged additional facts concerning her continued involvement
with Scientology from 2004 to July 2008, purported threats and intimidation by
Scientology during that time period, and her continued vulnerability to such threats and
intimidation.
Scientology demurred to the. second amended complaint based on the statute of
limitations. Scientology argued that plaintiff had failed to allege a basis for delayed
5
~

e .
discovery after 2004. It also argued that equitable estoppel and equitable tolling were
inapplicable and that, under the doctrine of collateral estoppel, the federal court's
decision precluded plaintiff's reliance on either equitable estoppel or equitable tolling.
Plaintiff again filed opposition. At the hearing on the demurrer, the trial court stated
that (1) collateral estoppel was inapplicable, (2) each cause of action accrued on
January 1, 2005, at the latest, and (3) the facts alleged in the complaint compelled the
conclusion that plaintiff had reason to suspect wrongdoing at that time. The court
therefore concluded that the limitations period had run on each co'unt before the filing of
the original complaint in April 2009 and sustained the demurrer to all counts, this time
without leave to amend.
Religious Technology Center then filed its demurrer to the second amended
complaint based on the same grounds asserted by Scientology. The trial court sustained
that demurrer as to all counts without leave to amend and dismissed the complaint in its
entirety. Plaintiff filed a timely appeal from the order of dismissal.
1
CONTENTIONS
Plaintiff contends (1) she adequately had alleged delayed discovery of each count
alleged in the complaint, so the causes of action did not accrue until 2004;
(2) defendants are equitably estopped from asserting the statute of limitations for the
period from 2004 to July 2008 because (a) they falsely represented that the documents
she signed released them from liability and (b) they threatened and intimidated her;
A signed order of dismissal is an appealable judgment. (Code Civ. Proc.,
581d, 904.1, subd. (a)(l).)
6
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~
,.,.,
~ !

(3) she is entitled to leave to amend her complaint to allege additional facts establishing
a basis for equitable estoppel, if necessary; and (4) collateral estoppel is inapplicable.
DISCUSSION
I. Standard of Review
"A demurrer tests the legal sufficiency of the factual allegations in a complaint.
We independently review the sustaining of a demurrer and determine de nova whether
the complaint alleges facts sufficient to state a cause of action. (McCall v. PacifiCare of
Cal., Inc. (2001) 25 Cal.4th 412, 415 [106 Cal.Rptr.2d 271, 21P.3d1189].) We assume
the truth of the properly pleaded factual allegations; facts that reasonably can be inferred
from those expressly pleaded, and matters of which judicial notice has been taken.
(Schifando v. City of Los Angeles (2003) 31 Cal.4th 1074, 1081 [6 Cal.Rptr.3d 457,
79 P.3d 569].) We construe the pleading in a reasonable manner and read the
allegations in context. (Ibid) We will affirm the judgment if it is correct for any
reason, regardless of the trial court's stated reasons. (Aubry v. Tri-City Hospital Dist.
(1992) 2 Cal.4th 962, 967 [9 Cal.Rptr.2d 92, 831P.2d317].)" (MKB Management, Inc.
v. Melikian (2010) 184 Cal.App.4th 796, 802.)
It is an abuse of discretion to sustain a demurrer without leave to amend if there
is a reasonable probability that the defect can be cured by amendment. (Schifando v.
City of Los Angeles, supra, 31 Cal. 4th at p. 1082.) The burden is on the plaintiff to
demonstrate.how the complaint can be arp.ended to state a valid cause of action. (Ibid)
The plaintiff may make that showing for the first time on appeal. (Care au & Co. v.
Security Pacific Business Credit, Inc. (1990) 222 Cal.App.3d 1371, 1386.)
7

2. Plaintiff Adequately Alleges Delayed Discovery Until 2004
"A cause of action ordinarily accrues when the wrongful act occurs, the liability
arises, and the plaintiff is entitled.to prosecute an action. (Howard Jarvis Taxpayers
Assn. v. City of La Habra (2001) 25 Cal.4th 809, 815 [107 Cal.Rptr.2d 369, 23 P.3d
601]; Norgartv. Upjohn Co. (1999) 21Cal.4th383, 397 [87 Cal.Rptr.id 453, 981 P.2d
79].) In other words, a cause of action accrues ' " ' "upon the occurrence of the last
element essential to the cause of action." '"' (Howard Jarvis, supra, at p. 815.) The
common law delayed discovery rule is an exception to the general rule and provides that
a cause of action does not accrue until a plaintiff discovers, or reasonably should
discover, the cause of action. 'A plaintiff has reason to discover a cause of action when
he or she "has reason at least to suspect a factual basis for its elements." [Citations.]'
(Fox v. Ethicon Endo-Surgery, Inc. (2005) 35 Cal.4th 797, 807 [27 Cal.Rptr.3d 661,
110 P.3d 914].) The elements that the plaintiff must suspect are the generic elements of
wrongdoing, causation, and harm. (Ibid) A plaintiff who suspects that he or she has
suffered an injury caused by the wrongdoing of another is charged with the knowledge
that a reasonable investigation would reveal, and the limitations period begins to run at
that time. (Fox, at pp. 807-808 & fn. 2.)" (Ovando v. County of Los Angeles (2008)
159 Cal.App.4th 42, 66, fn. omitted.)
The delayed discovery rule may apply in cases where, due to some disability or
other circumstances, the plaintiff is unable to comprehend the wrongdoing or the
resulting injury. (Parsons v. Tickner (1995) 31 Cal.App.4th 1513, 1526.) In some
circumstances, the nature of the relationship between the plaintiff and the defendant,
8

and the plaintiffs dependency and vulnerability, may prevent the plaintiff from
becoming aware of the wrongfulness of the defendant's conduct.
KJ. v. Arcadia Unified School Dist. (2009) 172 Cal.App.4th 1229 involved an
action for damages for childhood sexual abuse. The plaintiff alleged that her
dependency on and affection for her former school teacher prevented her from realizing
the wrongfulness of his conduct. We held that those allegations were sufficient to
invoke the delayed discovery rule for pleading purposes. (Id. at p. 1243.) Similarly,
Curtis T. v. County of Los Angeles (2004) 123 Cal.App.4th 1405, 1421-1423, held that
an alleged childhood molestation victim should be granted leave to amend his complaint
to allege that his youth, ignorance, and inexperience, and his foster parent's alleged
compllcity in the abuse, prevented him from realizing the wrongfulness of the conduct,
so as to invoke the delayed discovery rule.
The trial court here assumed without deciding that the delayed discovery rule
applied and that, as a result, the_ causes of action accrued on January 1, 2005, at the
latest We conclude that plaintiff had adequately alleged that, because of her isolation
from a young age, limited education, and restrictions on her personal freedom, she had
no reason to suspect that she was injured by defendants' wrongdoing until at or about
the time that she left the facility in 2004. Her causes of action therefore accrued in 2004
) . . ~ at the latest, and the limitations periods began to run at that time. The timeliness of her
complaint therefore depends on whether she had adequately alleged a basis for equitable
estoppel precluding defendants' reliance on a statute of limitation defense.
, ... _ ...
9
3. Plaintiff Has Adequately Alleged Conduct by Defendants Establishing
A Basis for Equitable Estoppel After 2004
A defendant may be estopped from asserting a limitations period as a defense if
the defendant's representation or other conduct caused the plaintiff to refrain from filing
a timely suit and the plaintiff's reliance on the defendant's conduct was reasonable.
(Lantzy v. Centex Homes (2003) 31 Cal.4th 363, 384-385 (Lantzy).) In order to support
an estoppel, the defendant's representation must be a representation of fact, rather than
a representation oflaw or denial oflegal liability. (Id. at p. 384, fn. 18; Vu v. Prudential
Property & Casualty Ins. Co. (2001) 26 Cal.4th 1142, 1152 (Vu).)
"One aspect of equitable estoppel is codified in Evidence Code section 623,
which provides that '[w]henever a party has, by his own statement or conduct,
intentionally and deliberately led another to believe a particular thing true and to act
upon such belief, he is not, in any litigation arising out of such statement or conduct,
permitted to contradict it.' [Citation.] But' "[a]n estoppel may arise although there
was no designed fraud on the part of the person sought to be estopped. [Citation.] To
create an equitable estoppel, 'it is enough if the party has been induced to refrain from
using such means or taking such action as lay in his power, ~ y which he might have
retrieved his position and saved himself from loss.' ... ' . . . Where the delay in
commencing action is induced by the conduct of the defendant it cannot be availed of
C; by him as a defense.'"' [Citations.]" (Lantzy, supra, 31 Cal.4th at p. 384.)
'.,,,
Equitable estoppel ordinarily arises from misleading statements about the need
for or advisability of bringing suit, but estoppel can also arise fro:in the defendant's
10
e
threats or intimidation that prevent the timely filing of a suit. (John R. v. Oakland
Unified School Dist. (1989) 48 Cal.3d 438, 445; Doe v. Bakers.field City School Dist.
(2006) 136 Cal.App.4th 556, 567.) The plaintiffs reliance on the defendant's conduct
must be reasonable to justify an estoppel, and the plaintiff must file suit within
a reasonable time after the effect of the events giving- rise to the es:toppel has ended.
(Lantzy, supra, 31 Cal.4th at pp. 384-385; John R., supra, 48 Cal.3d at p. 446.) These
are questions of fact for the trier of fact to decide based on the evidence. (John R.,
supra, at p. 446; Driscoll v. City of Los Angeles (1967) 67 Cal.2d 297, 305; see Vu,
supra, 26 Cal.4th at p. 1153.) A factual basis for equitable estoppel mustbe alleged
with sufficient particularity to disclose the facts relied upon. (Safranek v. County of
Merced(2007) 146Cal.App.4th1238, 1250.)
Plaintiff alleged in her second amended complaint that she worked and resided at
Scientology's facilities from the age of 12 until she was 25 years old, that she was
isolated from mainstream society and deprived of her personal freedom, and that she
was "brainwashed" and did not comprehend her legal rights. She alleged that (1) she
was forced to work in harsh conditions and subjected to punishment; (2) at the time she
terminated her employment and left the facility in 0 0 4 ~ she was required to sign
documents purporting to exculpate defendants and requiring her to keep certain
~ information c0n.fidential or suffer penalties and fines; (3) defendants knew that those
documents were contrary to law and unenforceable, and that defendants intended to
intimidate her into believing that she had no legal rights against them; (4) she was told
at that time that she owed defendants approximately $120,000 for her job training;
11
. ~

(5) she remained a loyal Scientology follower until July 2008 and that, as a loyal
follower, she was forbidden from reading or thinking anything negative about
Scientology; (6) she was threatened with harassment and banishment from her family
and friends who remained at the Scientology facilities if she were deemed an enemy of
Scientology; (7) after leaving the facility, she made payments on her purported debt for
some time because she believed that she was obligated to do so and she reasonably
believed that she had no legal rights or claims against defendants because of their
representations concerning the documents that she had signed; and (8) she first realized
in July 2008 that she might have legal claims against defendants despite the documents
she had previously signed, when she happened upon some information on the Internet
and her family members then shared their concerns.
While it is arguably true that defendants' alleged representations concerning the
legal effect of documents that plaintiff signed amount to a denial of legal liability -
which is not sufficient to support a claim of equitable estoppel (Lantzy, supra,
31 Cal.4th at p. 384, fn. 18; Vu, supra, 26 Cal.4th atp. 1152)-plaintiffhas alleged
more than simply defendants' denial ofliability. She has also alleged threats of
banishment and harassment. Plaintiff has further alleged that she was particularly
vulnerable to defendants' influence, both during her formative years as a child and
young adult, and after the time that she l ~ f t the facility when she remained an adherent.
In these circumstances, including particularly the context of her long subservient
relationship with Scientology, we believe that the alleged intimidation and threats of
banishment and harassment, if true, may preclude defendants, in equity, from asserting
12
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the statute of limitations as a defense. Although plaintiff does not expressly allege that
the threats caused her to delay filing her complaint, the complaint reasonably construed
clearly so implies.
2
We therefore conclude that the factual allegations of the second ari:J.ended
complaint are sufficient for pleading purposes to support an equitable estoppel.
Whether plaintiff's reliance on the alleged threats was reasonable is a question of fact
for the trial court to decide based on the evidence produced at trial.
4. The Federal Judgment Does Not Establish Collateral Estoppel
Scientology argued in its demurrer to the second amended complaint that the
federal court's decision that Scientology was not equitably estopped from asserting the
statute of limitations as a defense was binding in this action under the doctrine of
collateral estoppel. The trial court concluded that collateral estoppel was inapplicable.
Whether collateral estoppel applies is a question of law that we review do novo.
(Jenkins v. County of Riverside (2006) 138 Cal.App.4th 593, 618; Roos v. Red (2005)
130 Cal.App.4th 870, 878.)
Collateral estoppel, or issue preclusion, precludes the relitigation of issues argued
and decided in prior proceedings. (Hernandez v. City of Pomona (2009) 46 Cal.4th 501,
511.) " 'Traditionally, we have applied the doctrine only if several threshold
requirements are fulfilled. First, the issue sought to be precluded from relitigation must
be identical to that decided in a former proceeding. Second, this issue must have been
2
In any event, upon remand, the plaintiff could move to make such allegation
explicit.
13
actually litigated in the former proceeding. Third, it must have been necessarily decided
in the former proceeding. Fourth, the decision in the former proceeding must be final
and on the merits. Finally, the party against whom preclusion is sought must be the
same as, or in privity with, the party to the former proceeding. [Citations. f [Citation.]"
(Ibid.) " 'The "identical issue" requirement addresses whether "identical factual
allegations" are at stake in the two proceedings, not whether the ultimate issues or
dispositions are the same. [Citation.]' [Citation.]" (Id. at pp. 511-512.)
A judgment of dismissal after the sustaining of a demurrer establishes
res judicata, or claim preclusion, but only to a limited extent. "(1) A judgment entered
after a general demurrer has been sustained 'is a judgment on the merits to the extent
that it adjudicates that the facts alleged do not constitute a cause of action, and will
accordingly, be a bar to a subsequent action alleging the same facts.' (2) '[E]ven
though different facts may be alleged in the second action, if the demurrer was sustained
in the first action on a ground equally applicable to the second, the former judgment will
also be a bar.' (3) 'If, on the other hand, new or additional facts are alleged that cure the
defects in the original pleading, it is settled that the former judgment is not a bar to the
subsequent action whether or not plaintiff had an opportunity to amend his complaint.' "
(Crowley v. Modern Faucet Mfg. Co. (1955) 44 Cal.2d 321, 323, quoting Keidatz v.
Albany (1952) 39 Cal.2d 826, 828; accord, Wells v. Marina City Properties, Inc. (1981)
29 Cal.3d 781, 789.)
Absent a compelling reason to apply a diffe:r:ent rule, substantially the same
analysis should apply with respect to collateral estoppel. Thus, a judgment after the
14
sustaining of a demurrer is a decision on the merits to the extent that it adjudicates that
the facts. alleged in the complaint do not constitute a valid cause of action. But if the
facts alleged in the later proceeding cure the defects of the complaint in.the prior
proceeding, the issues in the two proceedings are not identical. The determination of an
issue in connection with the sustaining of a demurrer does not establish collateral
estoppel if additional facts are alleged that cure the defects of the complaint in the prior
proceeding with respect to that issue.
3
Because a motion to dismiss for failure to state
a claim upon which relief can be granted (Fed. Rules Civ. Proc., rule 12(b)(6),
28 U.S.C.) is the federal equivalent to a demurrer for these purposes, this same rule
applies to a judgment after the granting of such a motion to dismiss.
A federal court ruling on a motion to dismiss for failure to state a claim decides
whether the complaint alleges facts sufficient to support a claim under a cognizable
legal theory. (Johnson v. Riverside Healthcare System, LP (9th Cir. 2008) 534 F.3d
1116, 1121-1122.) If the statute of limitations and equitable estoppel are at issue, the
court decides whether the complaint alleges facts disclosing a limitations bar and
3
Border Business Park, Inc. v. City of San Diego (2006) 142 Cal.App.4th 1538,
1565-1566, stated that the general rule that collateral estoppel precludes the relitigation
of issues that were actually litigated in a prior action, even if some factual matters or
legal arguments that could have been presented were not presented, applies to issues
that were actually liti&ated in connection with the sustaining of a demurrer. In our view,
consistent with the authorities cited above, an issue that was actually litigated in
connection with the sustaining of a demurrer is identical to an issue in a later
proceeding, as necessary to establish collateral estoppel, only if no new facts are alleged
in the later proceeding that cure the defects of the pleading in the prior action. Border
Business Park apparently involved additional legal arguments rather than additional
factual allegations (see ibid), so that opinion is distinguishable.
15
whether it alleges facts showing a basis for equitable estoppel. (Trans-Spec Truck.
Service, Inc. v. Caterpillar Inc. (1st Cir. 2008) 524 F.3d 315, 320.) A federal court
ruling on such a motion does not decide whether the requirements for equitable estoppel
are established as a matter of fact, but only decides whether the facts alleged in the
complaint, if true, could warrant the application of equitable estoppel. (Ibid.)
The federal court in this case concluded that the facts alleged in the first amended
complaint compelled the conclusion that plaintiff's reliance on Scientology's
representations was unreasonable .. The federal court made no factual finding as to the
reasonableness of plaintiff's reliance. In her second amended complaint, plaintiff has
alleged additional facts concerning her reliance apart from those alleged in the first
amended complaint that was before the federal court. She alleges for the first time in
her second amended complaint that (1) during the time of her employment by
Scientology she was "brainwashed" by defendants and had no comprehension of her
legal rights; (2) she remained a loyal follower of Scientology from 2004 to July 2008;
(3) as a loyal follower she was forbidden from reading or thinking anything negative
about Scientology and was threatened with banishment and harassment if she were
deemed an enemy of the organization; (4) she reasonably believed that she had no legal
rights or claims against defendants because of their representations concerning the
~ : documents that she signed; and (5) she overcame her fears and first realized that she
might have legal claims against defendants, despite the documents that she signed, in
July 2008, when she discovered information on the Internet and discussed the matter
with family members.
16
These additional facts, together with the facts previously alleged and restated in
the second amended complaint, plead a basis for reasonable reliance sufficient to
support a claim of equitable estoppel. Any deficiency in the first amended complaint as
to reasonable reliance is cured by the additional allegations in the second amended
complaint. In light of the additional allegations, the issue decided by the federal court
based on the prior allegations is not identical to the issue presented here, so collateral
estoppel does not apply.
4
4
Plaintiff also argues that collateral estoppel is inapplicable for other reasons that
we need not address in light of our conclusion.
17
. i
DISPOSITION
The judgment is reversed with directions to the trial court .to vacate the order
sustaining the demurrer to the second amended complaint without leave to amend and
enter a new order overruling the demurrer to each count. Plaintiff is entitled to recover
her costs on appeal.
.NOT TO BE PUBUSHED IN THE OFFICIAL REPORTS
CROSKEY,J.
WE CONCUR:
KLEIN, P. J.
~ :
KJTCHING, J.
18
EXHIBIT 11
e
Laura Ann DeCrescenzo v. Church of Scientology International, ct al.
Stace Dieckman
Plaintiff,
versus
Defendants.
DEPOSITION OF: STACE DIECKMAN
No. BC411018
www.millerreporters.com EXHIBIT 1 1
e
Laura Ann DeCrescenzo v. Church of Scientology International, et al. Stace Dieckman
09:01:28 I
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MS. SMOLOWITZ: Sindee Smolowitz of 09:03:11 I Q And, in turn, if! ask a question that you
Blumberg Law on behalfofplaintiffand the witness. 09:03:15 2 answer, I'm going to operate under the assumption
MR. HINKS: Matthew Hinks, Jeffer Mangels 09:03:20 3 that you understood the question in its plain
Butler & Mitchell on behalf of RTC. 09:03:22 4 meaning. Is that fair?
MR. LIEBERMAN: Eric Lieberman on behalfof 09:03:24 5 A Yeah.
Church of Scientology International. 09:03:24 6 Q Okay. I placed before you a document which
MR. DEIXLER: Bert Deixler of Kendall Brill 09:03:28 7 we have marked exhibit numbered 51.
& Klieger on behalf of the Church of Scientology 09:03:31 8 (The document referred to was marked as
International. 09:03:31 9 Defendants' Exhibit 51 by the Reporter.)
THE VIDEOGRAPHER: Thank you. And the 09:03:31 10 BY MR. DEIXLER:
court reporter will please swear in the witness. 09:03:31 II Q Have you seen that document before?
09:03:33 12 A Yes.
STACE DIECKMAN, 09:03:33 13 Q And when did you last see it?
having declared under penalty 09:03:36 14 A I was emailed that about a week ago.
of perjury to tell the truth, was 09:03:39 15 Q Okay. And did you read it?
examined and testified as follows: 09:03:46 16 A I looked over it. I didn't read every word
09:03:49 17 of it.
EXAMINATION 09:03:49 18 Q Okay. Let me ask you to -- it's okay to
BY MR. DEIXLER: 09:03:52 19 touch it.
Q Good morning, Mr. Dieckman. 09:03:53 20 A Okay.
A Good morning. 09:03:55 21 Q Let me ask you to take a look at page --
Q You understand your testimony today is 09:03:57 22 starting at page 5 through page 7, "DEMANDS FOR
under oath and subject to the penalty of perjury? 09:03:59 23 PRODUCTION."
A Yes. 09:04:11 24 And there are, as I recall, 16 categories
Q How did you prepare for your deposition? 09:04:13 25 of documents --
Page 6 Page 8
A I met with Sindee and my family. 09:04:14 I A Right.
Q When was that? 09:04:15 2 Q - that are identified in there?
A Sunday. 09:04:17 3 A Yes.
Q And how much time did you spend in that 09:04:18 4 Q Do you remember seeing those before? Yes?
meeting? 09:04:19 5 A Yes.
A Hour and a half. 09:04:19 6 Q Okay. Here's another rule that we have to
Q Were you there from the beginning until the 09:04:21 7 agree upon.
end of the meeting? 09:04:23 8 In order for the court reporter to make the
A From the beginning I don't think to the 09:04:26 9 record of what I ask and what you testify to, you
end, no. 09:04:28 10 and I will each have to engage in verbal
Q Okay. Did you leave early or arrive late 09:04:31 II communications, using words rather than gestures or
or both? 09:04:37 12 noises.
A I left early. 09:04:38 13 A Okay.
Q Okay. And who did the bulk of the talking 09:04:38 14 Q So if you will adhere to that, it will make
in that meeting? 09:04:42 15 the court reporter's job so much easier.
A It was pretty spread evenly throughout the 09:04:45 16 A Okay.
people there. 09:04:46 17 Q All right. Then one last admonition.
Q Including yourself; correct? 09:04:48 18 Also for the clarity of the record, we
A Yes. 09:04:51 19 should allow each other to finish speaking before
Q Okay. One of the responsibilities I have 09:04:55 20 the other commences; so please allow me to finish my
in examining you is to ask you questions that you 09:05:00 21 question before you begin your answer. I, in turn,
understand, and I will endeavor to do that. 09:05:06 22 will do all I can to not interrupt your answer with
If you don't understand a question, will 09:05:08 23 another question.
you please tell me that? 09:05:09 24 Is that a fair deal?
A Yeah. 09:05:10 25 A Yeah.
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I upset about her time in the Sea Org?
2 A Yes.
3 Q When did she tell you that for the first
4 time?
5 A 2009.
6 Q And where were you when she told you for
7 the very first time that she was upset?
8 A At her house.
9 Q And who else was present?
IO A Her kids.
11 Q Her kids.
12 A Yeah.
13 Q Okay. And anybody else?
14 A Nope.
15 Q So just the children and Laura and
16 Uncle Stace?
17 A Yes.
18 Q Okay. You spending some quality uncle time
19 with the children?
20 A Yeah.
21 Q Okay. And was there any other reason for
22 you to be there in 2009?
23 A I was working in that area -
24 Q Okay.
25 A - and took a lunch break, and I went to
Page 58
I her house.
2 Q Okay. And tell me how the topic of her
3 unhappiness arose.
4 A I don't recall.
5 Q Well, did you say "Hey, Sis, you're looking
6 kind of glum. With these two lovely kids, I would
7 have thought you would have been super happy," or
8 words to that effect?
9 MS. SMOLOWITZ: Objection. Lacks
I 0 foundation.
I I THE WITNESS: I -- I don't recall what I
12 said --
13 BY MR. DEIXLER:
14 Q Okay.
15 A - or how it came about.
16 Q Okay. Tell me -- how long did the
17 conversation last on the topic of her feelings?
18 A 20 minutes.
19 Q Okay. Andcanyourememberhow-you
20 know, what words were spoken by each of you?
21 A No.
22 Q Okay. Can you remember anything other than
23 her saying she was upset?
24 A Just that she was upset. I could see that.
25 Q Okay. And -- and what was she doing? What
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Stace Dieckman
I were the physical manifestations of the upset that
2 you observed in 2009?
3 A Her demeanor was just sad. She was - she
4 was sad.
5 Q Okay. And - and how did that manifest
6 itself?
7 A By looking sad.
8 Q Okay. Crying?
9 A She wasn't crying, no, but she did look
I 0 sad, and her voice was affected.
11 Q And -- and how was her voice affected?
12 A It sounded like she was going the cry.
13 Q Uh-huh.
14 And had you ever seen her sad before?
15 A Yeah.
16 Q When had you seen her sad?
17 A I don't recall specific times.
18 Q Do you remember seeing her being sad when
19 she came home for visits from the Sea Org?
20 A When she was here for my sister's wedding,
21 she was very reserved.
22 Q Reserved?
23 And is that different from sad?
24 A Yeah.
25 Q Okay. Do you think your dad is reserved?
Page 60
I A Yeah.
2 Q You think he's sad?
3 A No.
4 Q Okay. So she - which sister was getting
5 married?
6 A Stephanie.
7 Q Okay. And you remember when that wedding
8 was?
9 A No.
I 0 Q But while your sister was on the RPF?
11 A Yeah. It was in 2002.
12 Q Okay. So your sister Stephanie got married
13 in 2002, and you observed that your sister Laura was
14 reserved.
15 Any other times that you can recall
16 observing her, prior to 2009, seeming sad to you?
17 A Not specifically, no.
18 Q Okay. Can you recall generally having seen
19 her sad?
20 A I just remember seeing her when she first
21 came back, and she seemed lost.
22 Q Seemed lost.
23 A Yeah.
24 Q What do you mean by that?
25 A She didn't know what to do, basically,
Page 61
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Laura Ann DeCrescenzo v. Church of Scientology International, et al. Stace Dieckman
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because she wasn't in the Sea Org having to do 09:58:55 I concluded that she was sad?
something all of the time. 09:59:01 2 A Cao you repeat that?
Q Uh-huh. 09:59:02 3 MR. DEIXLER: Sure.
It was as though she were unemployed? 09:59:14 4 (The record was read.)
A No. That's- 09:59:20 5 THE WITNESS: Yes. When we were in
Q No? 09:59:22 6 Puerto Rico together.
A -- that's definitely different. 09:59:23 7 BY MR. DEIXLER:
Q She didn't have a place to go every day? 09:59:23 8 Q Okay. And that was when she was working in
A She wasn't being made to do something. 09:59:25 9 the jewelry business?
Q Uh-huh. 09:59:27 IO A No.
And - and that led you to perceive that 09:59:27 11 Q What was she doing in Puerto Rico?
your sister was feeling lost; correct? 09:59:30 12 A Second Chance program.
A That, and she just didn't have any basic 09:59:32 13 Q Second Chance.
knowledge outside of what's - what's io 09:59:33 14 What were you doing in Puerto Rico?
Scientology. 09:59:35 15 A Second Chance program.
Q Basic knowledge of what? 09:59:36 16 Q How did you get that position?
A How to maintain her finances, bow to drive. 09:59:38 17 A From Laura.
Q And -- but she didn't seem sad? She just 09:59:39 18 Q Okay. And what was your work in connection
seemed lost? 09:59:42 19 with Second Chance?
A Yeah. 09:59:43 20 A I was corrections officer.
Q Okay. Did you remember talking to her? I 09:59:47 21 Q Okay. Did you like that job?
mean, you were living together at this time; yes? 09:59:49 . 22 A That's what I went and trained for; so -
A Yeah. 09:59:53 23 Q And so the answer is yes, you liked that
Q And do you remember sitting with her and 09:59:55 24 job?
saying "Hey, Sis, you seem lost. Do you want to 09:59:55 25 A No.
Page 62 Page 64
talk about it?" 09:59:56 I Q You didn't like that job?
A Nope. 09:59:57 2 A No.
Q How come? 09:59:57 3 Q Okay. How long did you hold that job?
A Because I knew why. 09:59:59 4 A At Second Chance?
Q You knew why? 10:00:01 5 Q Yeah.
A She was lost. 10:00:02 6 A A month.
Q Okay. 10:00:04 7 Q And what happened?
A She had been in the Sea Org since she was 10:00:07 8 A They didn't need a corrections officer
12. 10:00:09 9 anymore.
Q Okay. And you were - you were still a 10:00:11 IO Q Okay. And so you came home?
member of staff in 2004; right? 10:00:14 II A Yeah.
A Yes. 10:00:14 12 Q All right And tell me, if you will, about
Q Okay. 10:00:17 13 your conversation or conversations in Puerto Rico
A Technically. 10:00:22 14 with your sister.
Q Did you feel lost yourself? 10:00:29 15 MS. SMOLOWITZ: Objection. Overbroad.
A Me? 10:00:30 16 Vague and ambiguous.
Q Yeah. 10:00:32 17 THE WITNESS: I don't recall any specific
A Somewhat, yes. 10:00:35 18 conversation.
Q Yeah? You don't feel lost anymore, do you? 10:00:35 19 BY MR. DEIXLER:
A No. 10:00:37 20 Q Do -- you remember discussing with her her
Q You're --you're found at this point? 10:00:39 21 feelings after she had left the Sea Org; right?
A Yeah. 10:00:43 22 A Yeah.
Q Okay. Can you recall any conversation with 10:00:43 23 Q Okay. What do you remember her saying
your sister prior to 2009 in which, based upon 10:00:45 24 about her feelings in Puerto Rico after she had left
anything she said or anything you observed, that you 10:00:49 25 the Sea Org?
Page 63 Page 65
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her in Puerto Rico and the conversation you 10:21:03 I basically getting along, notwithstanding the fact
testified about in 2009, was there another occasion 10:21:07 2 that one of the four of you was a teenager?
in which she said to you that she was upset about 10:21:10 3 A Yes.
her experiences on the Sea Org? 10:21:11 4
Q
Without making it personal.
A No. 10:21:13 5 A Yes.
Q Okay. During the time you lived with -- 10:21:13 6
Q
Okay. And so you would talk about whatever
how long did you and your sister live together in 10:21:16 7 you would talk about; correct?
2004 when she returned? 10:21:18 8 A Yeah.
A Until I went back to Florida. I don't - I 10:21:19 9
Q All right. Now, after your sister came
don't recall when that was, though. 10:21:24 10 home in 2004, did she ever tell you that she had
Q Toward the end of2005 maybe? 10:21:31 II been contacted by former Sea Org members or other
A No. It would have been in 2004. 10:21:37 12 Scientologists?
Q 2004? 10:21:45 13 A No.
A Yeah. 10:21:46 14
Q
Okay.
Q So you lived together for several months 10:21:47 15 A I saw her talking to people but -
right after she returned? 10:21:49 16
Q Did you know that they were Scientologists?
A Yeah. 10:21:52 17 A Yes. Because she was talking about her
Q And you can't remember a single instance in 10:21:55 18 freeloader debt.
which, in that time period, she expressed to you any 10:21:56 19
Q Okay. And how many such conversations did
upset, discontent, or unhappiness; is that true? 10:21:59 20 you observe?
A Right. 10:22:02 21 A Three.
Q Okay. And you didn't perceive it at all; 10:22:02 22
Q Okay. What's freeloader debt?
correct? 10:22:06 23 A It's an imaginary number of money that she
A She wasn't eating a lot. That was the only 10:22:11 24 owes.
thing that was a little weird to me. 10:22:13 25
Q
Uh-huh.
Page 70 Page 72
Q Uh-huh. 10:22:13 I And other than it being an imaginary number
A She was real skinny. 10:22:17 2 of money that your sister owes, does -- did you have
Q Uh-huh. So a skinny, young woman? 10:22:20 3 an understanding of what the term meant?
A Yeah. 10:22:23 4 A Absolutely.
Q Okay. And did you feel you were close to 10:22:23 5 Q What does it mean?
your sister at that time? 10:22:25 6 A Freeloader debt?
A Yes. 10:22:27 7 Q Yes.
Q Okay. And do you think she was close to 10:22:28 8 A Means - well, in Scientology, it means
your mother? 10:22:34 9 that you are on staff and you got services. Then
A Yes. 10:22:36 10 you aren't on staff anymore. You broke your
Q Okay. Was she close to your dad? 10:22:40 11 contract
A Yeah. 10:22:40 12 Q And so you owe back the value of the
Q Okay. And so you were a good nuclear 10:22:42 13 services you received; correct?
family; correct? 10:22:44 14 A Yes.
MS. SMOLOWITZ: Objection. Lacks 10:22:45 15 Q Okay. And was that something you always
foundation. 10:22:46 16 knew about while you were on staff?
THE WITNESS: I don't understand nuclear 10:22:47 17 A Yes.
family. 10:22:48 18 Q Okay. So the notion of freeloader debt was
MS. SMOLOWITZ: You can answer. 10:22:51 19 something that was sort of part of the religion that
BY MR. DEIXLER: 10:22:53 20 you understood, from the time you joined the staff
Q You were -- 10:22:55 21 at least?
MS. SMOLOWITZ: Lacks foundation. Vague 10:22:56 22 A Every course that you do, you have to sign
and ambiguous. 10:22:58 23 something that says you understand it.
BY MR. DEIXLER: 10:23:00 24 Q Okay. And so you understood it; correct?
Q You were the four of you together, a lot, 10:23:03 25 A Absolutely.
Page 71 Page 73
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Stace Dieckman
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A I didn't want to bear from any
Scientologist anymore.
Q Okay. And especially not from your family
members; right?
A Correct.
Q Okay. You had about had it up to here of
being bossed around -
A Oh, way past there.
Q Way past there.
MR. DEIXLER: Indicating above his head and
not nearly to his neck.
MS. SMOLOWITZ: It's on video.
MR. DEIXLER: Okay. Let me just take a
break. I may be done.
THE VIDEOGRAPHER: We're going off the
record. The time is 11: 18.
{A brief recess was taken.)
THE VIDEOGRAPHER: We're back on the
record. The time is 11 :20.
MR. DEIXLER: No further questions.
MS. SMOLOWITZ: Standard stip?
THE WITNESS: All right.
MS. SMOLOWITZ: Regular stip?
THE VIDEOGRAPHER: Excuse me. This
concludes the deposition -- deposition of
Page 122
Stace Dieckman.
We are going off the record. The time is
11:20.
(It was stipulated among counsel
that the transcript will be sent to
Ms. Smolowitz's office; that
Ms. Smolowitz will be responsible for
the witness reviewing the transcript
within 30 days of receipt and of
providing all counsel with any changes,
comments, deletions within that time
period; that the witness will sign the
transcript under penalty of perjury; and
that the original transcript will be
made available for all proceedings in
this case; and if it is not available, a
certified copy can be used as if it were
the original transcript.)
(The deposition concluded at 11 :20 A.M.)
Ill
Ill
Page 123
I
2 I, STACE DIECKMAN, declare under
3 penalty of perjury that the foregoing
4 is true and correct, to the best of
5 my ability.
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9 Dated this _day of
10 2 0 1 ~
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12 New Mexico.
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STACE DIECKMAN
Page 124
I I, ALTHEA L. MILLER, CSR No. 3353, certify:
2 That the foregoing deposition of
3 STACE DIECKMAN was taken before me at the time and
4 place therein set forth, at which time the witness
5 declared under penalty of perjury to tell the truth;
6 That the testimony of the witness and all
7 objections made at the time of the deposition were
8 recorded stenograprucally by me and were reduced to
9 a computerized transcript under my direction;
10 That this transcript is a true record of
11 the testimony of the witness and of all objections
12 and colloquy made at the time of the deposition.
13 I further certify that I am neither counsel
14 for nor related to any party to said action nor
15 interested in the outcome.
16 The certification of this transcript does
17 not apply to any reproduction of the same by any
18 means unless under the direct control and/or
19 direction of the certifying deposition reporter.
20 IN WlTNESS WHEREOF, I have subscribed my
21 name this 30th day of July, 2012.
22
23
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ALTHEA L. MILLER, CSR No. 3353, RPR, CCRR
Page 125
32 (Pages 122 to 125)
(800) 487-6278
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.WPICASES\9527\SUM-JUDG\Declarations\2013-10-9 - Saldana Oecl.wpd
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES )
I am employed in the County of Los Angeles, State of California.
I am over the age of 18 years and am not a party to the within action. My
business address is 401 East Ocean Blvd., #800, Long Beach, CA 90802.
On October 9, 2013, I served the foregoing document, described
as: DECLARATION OF KATHRYN SALDANA IN SUPPORT OF PLAINTIFF'S OPPOSITION TO
DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND THAT THE
STATUTES OF LIMITATIONS BAR THE ACTION on the parties to this action as
follows:
(BY MAIL) I caused copies of such document, enclosed in
sealed envelopes, to be deposited in the mail at Long Beach, California
with postage thereon fully prepaid to the persons and addresses indicated
on the attached list. I am "readily familiar" with the firm's practice of
collecting and processing correspondence for mailing. It is deposited with
U.S. Postal Service on that same day in the ordinary course of business.
I am aware that on motion of any party served, service is presumed invalid
if the postal date or postage meter date is more than one day
after the date of deposit for mailing set forth in this affidavit.
(BY FACSIMILE) I served the foregoing document by faxing
true copies thereof from facsimile number (562) 436-1561, to the facsimile
numbers indicated on the attached list. Said document was transmitted by
facsimile transmission, which was reported complete and without error.
x (BY PERSONAL SERVICE) I caused to be delivered such
document by hand to the firms listed on the attached list where personal
service is indicated.
(BY E-MAIL) I delivered such document by electronic mail
to the firms listed on the attached list.
(BY OVERNIGHT MAIL) I caused such document to be delivered
to the firms indicated on the attached list by Express Mail or by another
express service carrier, by placing the document in an envelope designated
by the carrier and addressed as indicated on the attached list, with the
delivery fees provided for, and depositing same in a box or facility
regularly maintained by that carrier or by delivering same to an authorized
courier or driver authorized by the carrier to receive documents.
___lL (STATE) I declare under penalty of perjury under the laws
of the State of California that the above is true and correct.
(FEDERAL) I declare that I am employed in the offices of
a member of this court, at whose direction service was made .
Executed on October 9, 2013, at Long Beach, California.
Nina S. Vidal, Declarant
3
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ttWP\CASES\9527\SUMJUDG\Deciara1ions\2013-109 Saldana Deci.wpd
SERVICE LIST
(DeCrescenzo v. Church of Scientology, Case No. BC411018)
Bert H. Deixler, Esq.
Kendall Brill & Klieger LLP
10100 Santa Monica Blvd., Suite.1725
Los Angeles, CA 90067
(Church of Scientology International)
Matthew D. Hinks, Esq.
-ooo-
7 Jeffer, Mangels, Butler & Mitchell
1900 Avenue of the Stars, 7th Floor
8 Los Angeles, CA 90067-4308
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(Religious Tecqnology Center)
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.WP\CASES\9527\SUM-JUDG\D,ectarations\2013-10-9 _ Saldana Decl.wpd
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS.ANGELES )
I am employed in the County of Los Angeles, State of California.
I am over the age of 18 years and am not a party to the within action. My
business address is 401 East Ocean Blvd., #800, Long Beach, CA 90802.
On October 9, 2013, I served the foregoing document, described
as: DECLARATION OF KATHRYN SALDANA IN SUPPORT OF PLAINTIFF'S OPPOSITION TO
DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND THAT THE
STATUTES OF LIMITATIONS BAR THE ACTION on the parties to this action as
follows:
~ - X - (BY MAIL) I caused copies of such document, enclosed in
sealed envelopes, to be deposited in the mail at Long Beach, California
with postage thereon fully prepaid to the persons and addresses indicated
on the attached list. I am "readily familiar" with the firm's practice of
collecting and processing correspondence for mailing. It is deposited with
U.S. Postal Service on that same day in the ordinary course of business.
I am aware that on motion of any party served, service is presumed invalid
if the postal cancellation date or postage meter date is more than one day
after the date of deposit for mailing set forth in this affidavit.
~ ~ (BY FACSIMILE) I served the foregoing document by faxing
true copies thereof from facsimile number (562) 436-1561, to the facsimile
numbers indicated on the attached list. Said document was transmitted by
facsimile transmission, which was reported complete and without error.
(BY PERSONAL SERVICE) I caused to be delivered such
document by hand to the firms listed on the attached list where personal
service is indicated.
~ ~ (BY E-MAIL) I delivered such document by electronic mail
to the firms listed on the attached list.
~ - (BY OVERNIGHT MAIL) I caused such document to be delivered
to the firms indicated on the attached list by Express Mail or by another
express service carrier, by placing the document in an envelope designated
by the carrier and addressed as indicated on the attached list, with the
delivery fees provided for, and depositing same in a box or facility
regularly maintained by that carrier or by delivering same to an authorized
courier or driver authorized by the carrier to receive documents.
___x_ (STATE) I declare under penalty of perjury under the laws
of the State of California that the above is true and correct.
(FEDERAL) I declare t h ~ t I am employed in the off ices of
a member of this court, at whose direction service was made.
Executed on October 9, 2013, at Long Beach, California.
~ - - r---
Nina S. Vidal, Declarant
5
DECLARATION. OF KATHRYN SALDANA IN SUPPORT OF PLAINTIFF'S
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.WP\CASES\9527\SUM-JUDG\Declara1ions\2013-1G-9 - Saldana Decl.wpd
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aP\CASES\9527\SUM-JUDGIDeclarations\201J.10.9 Saldana Decl.wpd
SERVICE LIST
(DeCrescenzo v. Church of Scientology, Case No. BC411018)
Kendrick L. Moxon, Esq.
Moxon & Kobrin
3500 W. Olive Avenue, Suite 300
Burbank, CA 91505
(Church of Scientology International)
John P. Blumberg, Esq.
-ooo-
7 Blumberg Law Corporation
444 W. Ocean Blvd., Suite 1500
8 Long Beach, CA 90802
(Plaintiff)
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(Updated August 23, 2012 jlp)
7

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