Monique Rathbun V Scientology CSI S Anti SLAPP Motion Part 3

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EXHIBIT 19
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DECLARATION OF DANIEL MONTALVO
I, Daniel Montalvo, declare as follows:
I. I am over 18 years of age and a resident of the State of Colorado. I have
personal knowledge of the statement contained in this declaration and could competently
testify thereto, except where I have indicated that a statement is made on information and
belief, in which case I firmly believe the statement to be true.
2. In November 2007, I joined the staff of Bridge Publications, Inc. Over a
period of months prior to leaving Bridge, I downloaded confidential information of many
staffers at Bridge without authorization or permission. Using Internet Explorer, I was able
to access the entire FTP site.
3. I downloaded materials for several months prior to Sej)tember 2010 on to my
desktop computer. I also downloaded these private files onto several flash drives I
possessed.
4. I decided to leave Bridge staff in September 2010. At I hat time, I tried to
contact Tom DeVocht but I couldn't locate a working phone number for him. I called
Mike Rinder, whose number I found through Nexis-Lexis, and asked him for the phone
number of Tom DeVocht. DeVocht had been a friend of my parents when he was in the
Sea Org. I phoned Tom DeVocht and asked for his help to leave the Sea Organization and
Bridge staff. DeVocht agreed to help me.
S. I called DcVocht several times on Se tember 24, 20 IO, and DcVocht
arranged to have a fri end of his, Tiziano Lugli meet l!JJ with me I hat evening. DeVocht
informed me where lo meet TiziCtno Lugli al a Jack- in-lhe-Dox restaurant that was near lhe
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offices of Church of Scientology International in Ilollywood. When I arrived at Jack-in-
lhe-Dox, I was met u with by Tiziano Lugli and Marty Rathbun.
6. On Sc lcmbcr 24, 20 I 0, I was assigned to do some work al my desk during a
staff meeting, during which all of the other staff from Ilridge would be occupied and away
from my office. 13ridge Publications is located in Commerce, CA. Seizing u mn this
op Jortunily lo leave Bridge, I removed the five hard drives from my computer and
JJackaged them in a f ederal Ex ress box lo cany them. I also took fom fl ash drives with
me which contained Bridge files. Defore l lefi I called DeVocht and told him I was about
to leave Bridge and that I was taking several hard drives with me. I look a car belonging
lo Bridge and drove about 20 miles lo the offices of the Church of Scientology
International in Hollywood. DeVochl arranged for me to meet with Lugli al a Jack-in-the-
Box a cou le blocks away from the Church of Scientology International building in
l lollywood.
7. When l lell Bridge and went lo the Jack-in-the-Box, l mel up with Lugli and
Rathbun. I knew DeVocht had s )Oken to Rathbun about the hard drives because Rathbun
asked me irJ had taken the hard drives from Bridge. Both Lugli and Rathbun were full y
aware that I was mtting these stolen hard drives in their trunk. I did this so that security at
the church offices would not see me carrying anything and questi on me.
8. I arranged to drive Oridgc's car to the Church offices lo drop il off in their
>arking lol, and have Lugli and Rathbun pick me up a block away. I dropped the Oridgc
car off al the Church offices and walked from there north from Hollywood and Ivar to
Yucca Street where Lugli and Rathbun were JJarked, waiting for me. r gol into the car
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<rnd we drove off. After getling something to eat , we all went to Lugli's home where
Rathbun and his wife were also staying.
9. The next morning, I tried to access the hard drives on Tiziano Lugli's
computer. However, it was a Mac computer and the hard drives were Microsoft based.
Thus, they could not be opened. Lugli then had the idea of going over to Marc Headley's
house and drove me over to the Headley's home in Burbank, California, because Headley
had Windows 7 computers. When we arrived we went to Headley's home office and
Headley plugged one of the hard drives into his computer. I typed in the encryption codes
to unencrypt them, and each was accessed in turn. Headley copied some or all of the hard
drives onto his own computer.
10. At that time I remember feeling scared when over at Headley's house
because I was talking to Suppressive Persons (SPs) and I was concerned that these SPs
were copying Church information because I was concerned about how this would affect
me if I decided to go back to the Church.
11. As Headley was opening up the hard drives, he pulled up the file listings and
saw that private and confidential files were on these hard drives. This included
confidential session KRs (confidential ministerial notes of confessions), and internal
personnel records prepared by individual staff, known as a "Life History, " which contains
substantial confidential and personal information about those staff members. I saw
Headley downloading files from these drives, but I do not know if he downloaded all of
the hard drives or just parts thereof. I do know at one point I looked over and I saw
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copying and it was loading for awhile. It may have been my "Data" drive which
contained all the Bridge material plus anything else that I may have had on it.
12. I later s JOke to Lugli who told me that he had co Ji es of some of the
information downloaded by Headley. Exactly what Lugli eosscssed from I leadley -
downloaded from the stolen hard drives - I do not know but it was clear he had some of
the material. Later that day, aller Lugli and I had returned to Lugli's house, I did sec
Lugli give some CDs to Marty Rathbun. I don' t know for sure if these CDs contained
files downloaded from the hard drives at Ileadle_x's Jl ace.
13. On Se )fember 25, 2010
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Rathbun gave me an airline ti cket lo Oy to Plorida to
go to Tom DeVocht 's house. This was )aid for by Tiziano Lugli, but was reimbursed
through donations Rathbun collected. Rathbun Jaid for my cab fare to get lo the ainorl.
14. While al Lugli 's home, Lugli and Rathbun asked me to )OSC for a )icture
with a COJ2Y of Marc Headley's book "Blown for Good." After being arrested, Rathbun
vostcd it on his Internet website. I did not know the )hoto was going to be s )read on the
Internet.
15. In addition to the hard drives, I also took several flash drives with me that
contained confidential information from Bridge. Although I had allempled that day to
mail the hard drives back to Bridge, when we got to FedEx, the place was closed. Lugli
agreed to send them back to Bridge Publications. However, I kept the flash drives.
16. After I arrived in Florida, I was picked up at the airport by Tom DeVocht. I
stayed at DeVocht's house overnight, and the next day, went with my grandmother. I left
the satchel containing the flash drives at DeVocht's house. DeVocht told me later, that he
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had searched my possessions and found the flash drives, but said they were enc1ypted and
he was unable to open them. However, one of the flash drives had been loaned to me by
Dignus Lavooij, a Church of Scientology International staff member. That one was not
encrypted, and could have been accessed by De Vocht.
17. I came back to Los Angeles on October 6, 2010, and spoke to a Deputy
Sheriff who was investigating the theft, and was arrested. I was bailed out by Lugli, and
taken to live at the home of Jason Beghe. Beghe informed me after some months living
there, that Marc Headley had contacted him because he was worried about having
possession of the Bridge material on his hard drive, due to the fact that he [Headley] was
involved in litigation with the Church. Headley and Beghe arranged that Beghe would
take possession ofHeadley's hard drive containing the material he had downloaded from
the hard drives. Beghe told me he was going to hide the hard drive in one of several large
metal shipping containers located on his property. I did not confirm that this actually
happened, but I do know that Headley came to visit Beghe on a number of occasions after
Beghe told me that Headley was going to turn over the hard drives.
18. Months later, I spoke to Lugli and he told me that he had spoken to Tom
De Vocht who then informed Lugli that I had taken some flash drives. Lugli asked me
what was on the flash drives and when I told him there were a large number of life
histories he said he could have used them to contact family members of staff to cause
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problems and upset within fami lies using this confidential information.
I declare under penalty of pe1jury under the laws of the State of Colorado that the
foregoing is tme and correct.
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EXHIBIT 20
Free Dani el Montalvo I Moving On Up a Little Higher
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Moving On Up a Little Higher
Mark "Marty" Rathbun's Place
Free Daniel Montalvo
Posted on October 8. 2010 by martyrathbun09 I 366 Comments
hllp://markrathbtm. wordprcss.com/20 I 0/ I 0/08/ free-daniel-montal vo/
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Daniel Montalvo's first taste of freedom
About two weeks ago while I was taking a brief respite in the fmm of a wondetful evening at the home of Maty
Jo Leavitt, I received an urgent phone call from Tom Devocht.
Tom told me that he needed help with the escape of a 19-year-old staff member of Bridge Publications. Daniel
Montalvo never knew the outside world - having been in the Sea Org most of his life. Several months ago
Daniel and the rest of Bridge Publications staff were forced to read Miscavige's Freedom magazine attacking
myself, Mike Rinder, Amy Scobee, and Tom Devocht. Daniel knew it was garbage because of what the rag had
to say about Tom. He knew Tom (when Tom was CO CMO CW) when Daniel was a young child and
remembered him fondly for being so generous to and tolerant of children, including Daniel himself.
Consequently, Daniel searched the internet and, through my blog he found a means to get hold of Mike Rinder,
whom he figured correctly could (and did) get him in touch \\ith Tom. Daniel told Tom he could no longer take
the incessant stat push on books and tapes, the orders to cany out fraudulent practices against Scientology
public,and the Int-like DM tortures now being practiced by CMO PAC messengers regularly at Btidge
Publications. He said he knew nothing about the outside world, and knew vittually no one as never had a life
outside the Sea Org. Tom told Daniel he'd house him and employ him so that he could make a new statt if he
wished.
Daniel phoned that patticular Friday night because there was a CMO mission running a rein of terror through
Bridge for the usual down stats. All staff were being interrogated on the meter for outside connections and
influences. Daniel was ce1tain he could not get away with withholding that he was reading my blog and had
concluded that it contained nothing other than 100% gospel tmth.
Tiziano Lugli being my host in LA, and being the least PTS person I think I know on planet ea1th, bolted into
action. The kid only had a hand held text message sender and receiver, no phone. We coordinated his route
out, lost all om tails, and picked him up at a pre-designated spot.
We took him to a far away Deli and delighted at watching him eat a cheeseburger and fries "ith his eyes lit up
like he was ingesting an eight course gourmet feast prepared by Sinar Parmen himself.
Daniel brought a couple hard drives with him that contained music and may have been mixed with some other
Bridge traffic. We advised Daniel to return them to Bridge which he did via messenger senice. Then we got
Daniel on a flight to Florida to see Tom DV.
Tom and Daniel were beseiged by waves of Daniel's family members and OSA Flag staff using evety ploy and
threat possible to get Daniel to return. Tom fought them off like a she-gator protecting her young. After
suniving days of the onslaught, Daniel became intent on speaking with his mother. He phoned the church to
arrange this, but reception put him through to Kendrick Moxon - an alleged attorney. Moxon proceeded to lie
to Daniel that the hard drives were never returned, and made a convincing case (not difficult to do with a 19
year old who doesn't even know the three branches of government) that Daniel would be put behind iron bars
for a good long time, UNLESS of course, he returned and cooperated with Moxon and routed out properly.
Tom sagely advised Daniel that he would face only one of two fates should he return, a) be sent to jail, orb)
spend ten years in the RPF. After several sleepless nights and incessant badgering and threats from the
Free Daniel Montalvo I Moving On Up a Little Higher http://markrathbun. wordpress.conv'20 I 0/ I 0/08/free-daniel-montalvo/
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Daniel returned to LA to route out.
Daniel was picked up by an investigator in a bl ack car with blacked out windows. Instead of bei ng taken to a
hotel, where he could route out as promised, he was taken to the Centmy City Towers. He was deposited in an
offi ce on the 33rd floor where a pricy church lawyer interrogated him for two hours. Only then, did Moxon
come in and sta1t interrogating harder, demanding that Daniel finger Tiziano, Tom, and myself as the master
minds of his having taken hard drives from Bridge. Daniel explained that he could not say that because it is a
blatant lie. Quite the contra1y, Tom advised him not to take the hard drives and I advised him to return them
once I learned that he had ignored Tom's otiginal advice.
Moxon then said they would need to go the LA County Sheriffs office to clear eve1ything up. Ins tead of clearing
it up, Moxon pulled out a huge binder with shots and dossier's on Tom, Tiziano and myself. Moxon plied the
Sheriffs detective with a grand conspiracy theory, characterizing me as the "anti-christ" of the church of
Scientology. I guess Kingpin has become passe.
The next thing Daniel knows he's in a cell where he sat for the next 30 hours. Had it not been forTiziano
fronting $2,ooo through credit Daniel would be there now and for God knows how long.
David Miscavige - who I promise will go to j ail before this is all over - ordered Kendrick Moxon - whose bar
card I am now promising to take away - stabbed a nineteen year old slave in the back the second he got a whiff
of freedom. I have never heard of such low-life treache1y . And Lord knows I've seen my share of it under the
tutelage of the master of treache1y, David Miscavige.
Tiziano, Jamie Sorrentini, Tom, Mike Rinder, Jason Beghe and I have been worki ng in a fluny this afternoon to
get Daniel out of the LA County (East LA branch) j ail.
As of the minute I post this, Daniel walks free once again, at least temporarily, having been bailed out by Jamie
and Tiziano.
We ha\'e arranged for a coml!_etent attorney to re resent Daniel at his arraignment tomo1Tow.
I have been hesitant to raise money for our cause despite the need - recognizing how former church members
have been fl eeced to the bone over and over. However, my rule on that score doesn't apply to a 19 year old kid
facing the penitentiary in thanks for the foll owing sins:
a) Leaving a lifehood of slave1y to get a taste of freedom and the world.
b) Refusing - despite eve1y provocation and incentive and threat - to frame three guys who went out of their
ways (and dipped into their pockets) to help the kid achieve that freedom.
Accordingl}J I am creating t rn Free Daniel Montalvo Fund. We are hying to initially raise the 3,000 dollars
(bail and aitfares) we've already personally fronted) and another 5,000 for a retainer for a criminal lawyer
skilled and tough enough to take on the church and the LA County Sheriff Leroy D. Baca. Yes, the Sheriff
himself. Do you seriously think the church could get any other agency in the world to do the kind of illegal,
underhanded work they've gotten the Sheriff's Office to do? They wouldn't have a prayer without owning the
Sheriff himself. As to whether that is the case, I invite you all to peruse church promo over the past ten
Free Daniel Montalvo I Moving On Up a Little Higher http://markrathbtm.wordpress.conv20 I 0/ I 0/08/free-daniel-montalvo/
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Baca has extolled their vi1tues over and over - in exchange for getting to hob nob with Cruise, Travolta, Alley,
etc - even while dozens upon dozens of staff have been continually held in vitt ual bondage by the
very institution - in his jmisdiction - he lavishes with praise.
For now, if you are interested in conhibuting, you can go to my paypal account - under the donate section on
the front page of the blog, http://markrathbun.wordpress.com/donate/ . When you are prompted to wlite a
message with any donation, just put in Free Daniel Montalvo Fund. I'll keep exact accounting of s uch
designated funds.
Without you all, this young man would have already been crushed like a bug and forgotten. With you, he will
never be forgotten. I think this is one of those places where we are compelled by conscience to etch a very
distinct and durable line.
Free Daniel Montalvo!
EXHIBIT 21
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DECLARATION OF DANIBL MONTALVO
I, Daniel Montalvo, hereby declare:
l. I am over 18 years of age and a resident of the State of Colorado. I have
personal knowledge of the statements contained in this declaration and could competently
testify thereto, except where I have indicated that a statement is made on information and
belief, in which case I firmly believe the statement to be true.
2. I have been involved in several legal cases this past year. One was a
potential case against me related to computer hard drives and flash drives that I took
without authorization or permission when I left my work at Bridge Publications. John
Duran, an attorney referred to me by Jason Beghe, represented me in this case. I also
brought civil cases against Bridge Publications and the Church of Scientology
International.
3. I know a person named Marty Rathbun, who used to be a senior execulive
of the Church. Rathbun has attempted to get involved in my legal cases. He went to visit
my attorney, John Duran, to talk to him about my cases. Rathbun talked about the
Church and the Church's way of dealing with legal matters like the legal tactics the
Church would use in litigation. Jolm was not very interested and his reaction was "OK,
whatever." Rathbun was coming up with all these legal conclusions acting like he was the
boss and JoJm was like "You just let me do my job." John was not particularly fond of
Rathbun. I was living at Jason Beghe's home at the time. Rathbun and Mike Rindcr
were in town and they stayed over at Beghe's house one night in early December 20 l 0
and we talked about my cases. Rathbun and Rinder said they were very experienced with
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how the Church handles legal cases. They wanted to talk to my lawyer, John Duran, to
get him to "play hard with lhe Church" and lo have them and others testify for the
purpose of putting Scientology and the Church on trial, even though I was a potential
defendant in one case, and a defendant in another case, and the Church's actions were not
at issue in these cases. ML Duran did not agree with what Rathbun wanted aud thought
his suggestions were over the top.
4. Rathbun, who I have been informed was a "legal fighting guy" when he
worked for the Church, and Mike llinder, who used to be the head of the Office of
Special Affairs that handles legal matters, both became consultants to the attorney who
represented me in my civil case against Bridge and the Church. Prior to the suits being
filed, Rathbun and Rinder came to Beghe's house and met with me for some hours where
they talked to me about my involvement in the Church. They then came with me to meet
my civil attorney Kil Winter and rovided information to my attorney on the organization
of the Church, background and information about the Church of Scientology and legal
strategies used by the Church. Rathbun and Rinder a J arcntly had ex eriencc with the
Church's legal matters and could provide information about the way the legal system
worked within the Church and the way the Church uses the legal system. I was resent
for one meeting with my attorney where Rathbun and Rinder were present. It is my
understanding that after that meeting, my attorney s JOke with Rathbun and Rindcr on a
fow occasions outside my presence.
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5. I also sent the complaints, prior to them being filed, to Rathbun to review.
Shortly thereafter Rathbun posted about the filing of the cases, which resulted in the St.
Petersburg Times and other media running a story about the lawsuits.
I declare under the penalty of petjury under the laws of the State of Colorado that
the foregoing is true and correct.
Executed this
<. >
.S:: ..., day of December, 20 11 at Castle R-ock,
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EXHIBIT 22
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( I) Monique Banks Rathbun
Monique Banks Rathbun
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203 of616
https :// www. facebook.coml moni q ue. rnthbun?fref=ts&re f=br _ tf
~ ~ Mimi Armagh Parrow Bwahaha! I'd love to steal this but no one
~ \\ in the history of the world has ever told me I'm quiet!
July 12, 2012 at 9:31am via mobile Li ke 2
Lori Hodgson Loi !!!
July 12, 2012 at 9:38am via mobile Like
Lise O'Kane OMG .. .I feel naked . .like I've been found
out..hahaha ... have to share this one.
July 13, 2012 at 6:58am Like
I Write a comment ...
More and more exposure of the COS lies! Well done Babe!
Tom Cruise's former Sci entology
auditor speaks about
Cruise/Kidman divorce
rockcenter. msnbc. msn.com
By Anna SchecterRock Center Katie Holmes
and Tom Cruise's settlement is now final and
neit her of them have publicly addressed
reports that the Church of Scientology-and
the future role of Scientology In their
Like Comment Share July 11, 2012 at 12:4Spm
Lori Hodgson, Sam Domingo, Joy Graysen and 7 others like this.
3 shares
~ Sam Domingo cartwheels xxx
; July 11, 2012 at 12:52pm Like
~ Sam Domingo Spreading the word far and wide.
' July 11, 2012 at 12:54pm Like
f =.. l Monica Martinez-Salinas Wow is all I can say. I think Dianetics
l j is a very insightful book, but the way the current board has twisted
its informati on is disturbing.
July 11, 2012 at 1: 18pm via mobile Like
Joy Graysen Shared!
July 11, 2012 at 1:18pm via mobile Like
Carol Kramer Yes! I like it!! !
July 11, 2012 at 2: 09pm Li ke
Lori Hodgson I shared it too!!
July 11, 2012 at 3: 10pm Like
Wri te a comment...
RECENT ACTIVITY
"lol" on Natalie Hagemo' s photo.
Chat (Off)
(I) Monique Banks Rathbun
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258 of616
https://www.facebook.convmonique.rathbun?fref=ts&ref=br_tf
, March 2, 2012 at 9:33am via mobile Like
Renere Lopez Actually, it's because she knows I'll be there in a
week and she's getting excited ...
March 2, 2012 at 2:02pm via mobile Like 2
Missy Montana I love the adventures of cat!
March 2, 2012 at 2:24pm Li ke
fn1! carol Kramer tink you are precious ... you are such a lady
f l - . . ~ October 4, 2012 at 9:27am Like
[ Write a comment...
RECENT ACTIVITY
Monique likes Running with Scissors.
Monique and Tracy Lynn Ray are now friends. Like Comment Add Tracy as
Fri end
"Happy birthday Martin! ., M&M" on Martin Padfi eld's timeline.
Mimi Armagh Parrow
Word of warning, do not EVER go to !hop then do burpees!
Li ke Comment February 29, 2012 at 5:25pm
Monique Banks Rathbun LMAO! ! ! Never do anything heavy
before burpees ..... they are best done on an empty stomach!!!
February 29, 2012 at 5:38pm Like 1
~ Mimi Armagh Parrow OH my tummy became empty shortly
\ thereafter , Oy Vey!!
February 29, 2012 at 5:49pm Li ke
Monique Banks Rathbun Thats what they call a Pukie LOL
Mi mi Armagh Parrow Bwahaha, I was gonna say .... that was no
mere burp!
February 29, 2012 at 5:54pm Li ke
I Write a comment. ..
Good Morning America and later on Nightline ....... Will the big celebs{Tom
Cruise, John Travolta, Kirstie Alley) ever wake up and stop supporting this
abusive madman? How much more testimony of the abuses does the American
law enforcement need to shut them down? Geez!!!
Another PR Crisi s?
markrathbun.wordpress.com
ABC news Nightline dubs Miscavige's abuse and torture as Another
Scientology PR Crisis. Ya think? Tony Ortega at the Village Voice has
published a bunch of Cook litiqation related documents .. .
Like Comment Share February 29, 2012 at 5:57am
Natalie Hagemo, Tara Morgan Bryant, Dee ~ Chat (Off)
(I) Monique Banks Rathbtm
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288 of616
https ://www. facebook.convmonique. rathbun? fref=ts&ref=br _ tf
RECENT ACTIVITY
"Happy Valentine's day Mims!!! " on Mimi Armagh Parrow's post on Monique
Banks Rathbun's wall.
"Happy Birthday C.R.!! M&M" on C.r. Hodgson's timeline.
Monique is now friends with Mark Patterson and Keri Easton.
Mi mi Armagh Parrow
Hope you have a phenomenal weekend!XOXO
Li ke Comment February 11, 2012 at 2:14pm
Dee McMurdie likes this.
Monique Banks Rathbun Thanks Babe, Just recovering from all
the fireworks!! Slept till 12:30
February 11, 2012 at 2: 15pm Li ke 1
-1 Mimi Armagh Parrow The rest was well deserved! I went to
~ spin, came home & did burpees and went right back to bed, lol!
[ Write a comment. ..
Monique Banks Rathbun shared a hnk.
Scient ology I nc. v. Debbie Cook, Day 2
On going coverage: Village Voice updates from inside the courtroom
MikeBoard1200 Twitter feed from inside the courtroom I will be adding links
to the post as they become available. -Mosey
Li ke Comment Share February 10, 2012 at 7:11am
Pete Griffiths and Michelle Wentling like thi s.
1 share
OMG I am still awake and I have no idea why!!
J Li ke Comment Share February 10, 2012 at 3:29am
View 6 more comments
Mimi Armagh Parrow Yup 34! !
February 10, 2012 at 3:47am Like
Monique Banks Rathbun ok i can do that! Gonna try and get in
an hour or two of sleep before Day 2! ! Check with ya later
February 10, 2012 at 3:47am Like 2
-; Sara Finning you're on GMT (Greenwich Mean Tlme)
;.1("-4".'
~ February 10, 2012 at 4:53am Like
:J Mimi Armagh Parrow Holler or text if ... . . . .. __ .... ._, __ -- -' '
. ~ Chat {Off}
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294 of616
https ://www. facebook.convmonique.rathbrn1?fref=ts&ref=br _If
Friend
Hasta la vista B * % ~ " e s
http://www. texasmonthly .com/ 2012-02-0 l / letterf romi nglesideonthebay. Qhp
His Town
www .texasmonthly.com
When Marty Rathbun became an outspoken defector from
the Church of Scientology, a group of filmmakers began to
disrupt life in his adopted hometown. But they weren't
Like Comment Share January 26, 2012 at 8:45am near Ingleside, TX
Sinar Parman, Dee McMurdie and 2 others like this.
1 share
Amy Scobee Woohoo!
January 26, 2012 at 6:36pm Like
Dee McMurdie Yahl!!!!!
January 26, 2012 at 10:08pm Like
[ Write a comment ...
RECENT ACTIVITY
"She is just adorable!!!" on Mareka Backus's photo.
"Happy Birthday Linda!! M&M" on Linda Monnens-Mcginley' s timeline.
Mimi Armagh Parrow
I'm not in the ER *only* because I didn't have one of those "I've fallen and I
can't get up" buttons. I will never skip again.
Like Comment January 24, 2012 at S:Olam
Monique Banks Rathbun and Dee McMurdie like this.
RECENT ACTIVITY
"The Notebook was great ... ummm ... " on Mimi Armagh Parrow's status.
"I know!! It was so much easier ... " on Mimi Armagh Parrow's status.
"Ingleside Texas, Just started ... " on Li sa-Marie BodyRock.Tv Host's status.
Monique likes Abs Transformation with Yoot Tang.
Monique likes She Loves Basketball.
Monique Banks Rathbun shared Jerome Morgan Jr.'s photo.
WOW!! Food for thought!
Chat {Off)
(I) Monique Banks Rathbun
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334 of616
https ://www.facebook.com/ moni que. ra thbrn1?fref=ts &ref=br _ tf
More information on the crimes of the "Church of Scientology" that continue to
go unnoticed by authorities!!! Help wake up the Federal Government who are
supposed to be protecting citizens rights!!
If you have not signed the petition please do so, this is not about
religion ...... this is about basic human rights!!!
Why the Federal Government Must Be Held to
Account
Please see the documentation of illegal and
unconscionable conduct of David MiscaviQe's Radical
Like Comment Share October 16, 2011 at 6: 19am
Tara Morgan Bryant, Dee McMurdie and 2 others like this.
I Write a comment...
RECENT ACTIVITY
"Well done!!!! :-)" on Ziba Feulner's post on Marty Rathbun's wall.
Monigue Banks Rathbun
Another example of what this so called "church" is doing! Please read this
article, these are friends and well intentioned individuals!!!
WE CAN NOT LET THIS "CHURCH" GET AWAY WITH THIS!!!
SIGN THE PETITION! !!!
http:// wh.gov/ 40s
Scientology Hates Clean Ice, Part 2:
Another Target, and the Web as
Weapon
blogs.villagevoice.com
On Wednesday, we told you about a
Scientology
Like Comment Share October 14, 2011 at 9:08am
Sinar Parman, Laura Ann Fowler Wilson, Dee McMurdie and 3 others like
this.
Mareka Backus I can't believe they did that to Susan!! They are
fkn insane.
October 14, 2011 at 9:26am Like
Monique Banks Rathbun I can totally believe it, it's the same
crap they have been doing to everyone who has any connection to
Mike or Marty. I just can't believe they are allowed to get away with
it, I mean FFS ... enough already, how much proof do you need before
the authorities get off their asses!!!!!
October 14, 2011at9:30am Like 4
Karl a Zamudio We'll make it!
October 14, 2011 at 12:01pm Like
Chat (Off)
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(
335 of616
https ://www. face book. convmoni que. ra thbtm?fref=ts& re f=br - tf
Hello Lady ... it has been a long time ... you look amazing! Hope all is well!!! :-))) )
Li ke Comment October 13, 2011 at lO:OSam
Monique Banks Rathbun Yes things are really good! How are
things with you ...
October 13, 2011 at 11:42am Li ke
j Write a comment. ..
Recent example of how the "Church of Scientology" rips families apart. Heart
Breaking!! If you have not signed the petition ... Please do so!! No "church"
should be allowed to hid behind "religion" to get away with these abuses!!!
http://wh.gov 40s
Knowledge Report: Lori Hodgson on
Disconnection
www .youtube.com
Scientology's policy of Disconnection breaks up
families.
Li ke Comment Share October 12, 2011 at 6:34am
Dee McMurdie, Svetlana Shketik, Graham Berry and 4 others like this .
., Karla Zamudio just email over 100 people on my database got
Ill. 4 about 300 more to go ..... xo
October 14, 2011 at12:00am Like
I Write a comment...
Lori Hodgson
Scientology and Disconnection: 'No One's Going to Take My
Eternity Away'
biogs. villagevoice .com
Lori Hodgson keeps telling me she's going to give me the entire story of her
time in Scientoloqy. Well, I'm ...
Li ke Comment Share October 11, 2011 at 8:55am
Dee McMurdie, Graham Berry, Mary Elle and 2 ot hers like this.
Mareka Backus Disconnection sucks ass! Poor Lori, I hope her
kids see sense soon!
October 11, 2011 at 10:43am Li ke 3
Paul Jay Salemo Lori is seeing things more clearly day by day .... I
hope those poor kids break free of all the unhealthy influences that
they may be experiencing soon.
October 22, 2011 at 7:05pm Like
RECENT ACTIVITY
Monique likes Scientology Hates Clean Ice, P ~ Chat (Off)
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357 of616
https:// www. facebook.conv'monique. rathbtm?fref=ts&ref=br _ tf
This is what the "church of Scientology'' spends donation money on. Tracking
down our travel reservations and ambushing us at the airport in
Phoenix .... http://youtu.be/SxQolLCu700
If you have not already signed this petition, please do! No one should be
allowed to get away with this kind of behavior in the name of "religion".
http://wh.gov/40s ...
See More
http: / /www.youtu.be/ SxQolLCu700
www.youtu.be
Like Comment Share September 29, 2011 at 6:34am
I
Sam Domingo, Dee McMurdie and 2 others like this.
Laura Ann Fowler Wilson Jim doesn't know what to do when
confronted with Mosey and carol! Grrrrrrrr! You go girls!
September 29, 2011 at 7:22am Li ke
Jack Airey Get EM Mosey .. .! signed the P
September 29, 2011 at 8:09pm Like
Lauralee Hunnicutt
Your still an AMAZING person that I met when I was a kid, you ALWAYS had
the biggest heart! I hope we never lose contact again! xoxo
Like Comment September 28, 2011at9:13pm
Monique Banks Rathbun Nope!!! Never!!!!
September 29, 2011 at 5:48am Li ke 1
j Write a comment...
RECENT ACTIVITY
Monique and Tatiana Baklanova are now friends. Like Comment
To my FB friends and Family, Please read the attached petition and sign. Please
help to get the government to investigate the abusive and criminal behavior of
this "church''. What they are doing is wrong and should not be allowed to get
away with it. All you need is a valid email account, you can even just sign using
your first and last initials if you would prefer to remain anonymous! Help bring
justice for so many victims of the church! Thank you!! Currently at 1400 almost
halfway there!!
EXAMINE THE GOVERNMENT' S FAILURE TO
I NVESTIGATE AND PROSECUTE CHURCH OF
SCI ENTOLOGY CRIME, FRAI In ANn
wwws.whitehouse.gov j
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EXHIBIT 23
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Sneering, Whining and Lying - DM's Trademarks I Moving On Up a Little Higher
1nosey lo 2011 at 4.50 om f{f oly
My real concern is that as the "church" continues to lie to their members and opcrathes about
how "evil" Marty and the independents arc, seeing how deluded they already are, might do
something ,e1y stupid. Who is to say that one of these poor souls who are on some s01t of
ethics amends project or tl);ng to get on the next lewl of the bridge, or trying to be a hero that
DM will raise in stah1s, won't do something really crazy. I've looked Joanne Wheaton and Ed
Bryan in the eyes. They are deranged incli\;duals. The church is breeding these extremists.
Radicalism is dangerous. Look what was done in the name of Islam. My hope is that
"Scientologists" don't go the same route. Having been exterior to the situation all along and
simply watched what has played out before my eyes, I think it is nai\'e not to haw such
concerns.
Martin J July 16, 201 1 at5:07 prn J ~
Completely agree Mosey; this is a real concern, and why, despite eve1ything collectively we
need to see the goodness within all these people, even the raclicalisecl ones, and be ready
with help and support when needed. Pretty soon there ~ I I be a lot ofve1y confused and
disodentated SO and staff in particular who will need stable reference points and fri endly
arms. I have the wherewithal and willingness in my area to help house and support those in
genuine need.
splog J July 16, 2011 at 9:53 pm J ~
I promised myself a while ago that evmy now and then when this aspect comes up (SO
members find themselves with nowhere to go), I'd make an offer to help - sooner or
later old friends of mine will read this and maybe find themselves needing a helping
hand. The time has come around again.
Page 53of85
http://markrathbun.wordpress.com/2011/07I16/sneering-whining-and-lying-dms-trademar... 10/ 16/20 l 3
CAUSE NO. C-2013-1082B
MONIQUE RATHBUN,
Plaintiff,
v.
DAVID MISCA VIGE, RELIGIOUS
TECHNOLOGY CENTER,
CHURCH OF SCIENTOLOGY

INTERNATIONAL, STEVEN
GREGORY SLOAT, MONTY DRAKE,
DA VE LUBOW and ED BRYAN,
Defendants.
IN THE DISTRICT COURT
207TH JUDICIAL DISTRICT
COMAL COUNTY, TEXAS
AFFIDAVIT OF DA YID LUBOW
I, David Lubow, hereby declare and state:
I. I make the following statements of my own personal knowledge and if called to
testify thereto, I could and would do so competently.
2. I am a resident of Los Angeles County, California.
3. I am a licensed private investigator. I am also an independent documentary film
producer. I started my documentary film career in 2004. Because there was so much false and
derogatory information about me on the Internet arising out of my investigative work, I decided
to use the pen name David Stalter for my documentary work. My first documentary, which I
wrote and produced, was the feature length documentary Prescription: Suicide? addressing
psychiatric abuse of prescription medication with children. My film and producer credit can be
found on IMDB (Internet Movie Database, containing- the standard database for film makers
and movies) under the name David Stalter (Executive Producer: Prescription Suicide? 2005). In
November of2005, Prescription: Suicide? premiered at the Ft. Lauderdale International Film
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Festival where it won the "Spirit of Independents" award. The film has appeared in many other
film festivals across the US and Canada, including the Beverly Hills Film Festival, where it
received an Honorable Mention. The film has been seen by at least 600,000 people thus far. It is
currently for sale through a national distributor. As producer of the film, my responsibilities
included financing the film, writing scripts and dialog, hiring the director, editor and film crew
and arranging worldwide distribution. Through my international distributor, Prescription:
Suicide? has appeared on television stations in the USA, Canada, Israel, Norway, Finland,
Sweden, Brazil, The Middle East, Hungary and in Germany on ZDF as recently as August of
2013. After the success of Prescription: Suicide? I began work on a second film dealing with
the same issues. That sequel to Prescription: Suicide? is in pre-production.
4. Prior to 2009, I was retained by Los Angeles attorney Elliot Abelson on behalf of
his client, the Church of Scientology International ("CSI") to perform investigative actions in
support of litigation, prospective litigation and threatened litigation in which the CSI was or
could be involved. I was also retained to investigate potential violations of intellectual prope1ty
rights licensed to CSI relating to the Scientology religion.
5. This assignment arose in part out of public record research and investigation, in
which it was detennined that Mark ("Marty") Rathbun (sometimes hereinafter "Rathbun") was
potentially violating religious trademarks for which CSI is the exclusive licensee by delivering
an altered form of Scientology. Rathbun also made public statements on his blog in August
2010, exhorting Scientologists to steal church records from CSI or any other church available to
them, to bring the stolen materials to him and that he would "protect" the thieves as purported
whistleblowers. Rathbun was overtly working with persons involved in litigation with CSI,
Scientology parishioners and the Church of Scientology Flag Service Organization church and
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purporting to be a "consultant" to attorneys engaged in litigation with CSI and Flag Service
Organization. Mr. Abelson hired me on behalf of his client CS!, to investigate the matters
addressed in this paragraph respecting Mark Rathbun, and also to determine what facts might be
applicable to bringing both civil and criminal actions against Rathbun. I took direction from Mr.
Abelson and coordinated and reported to him or to staff at CSI. I have never reported nor
consulted with any staff member or representative of Religious Technology Center, nor with
David Miscavige, regarding any investigation relating to Rathbun. I have never met nor spoken
to Mr. Miscavige.
6. In the context of this assignment, I performed investigations regarding Mark
Rathbun. At no time did I or anyone working under my direction or in coordination with me,
undertake any unlawful actions or actions which would violate the privacy of Monique Rathbun.
Indeed, the investigation was targeted at Mark Rathbun, and Monique was at best tangentially
involved because she lived with Rathbun and she was engaged with him in the business of
delivering "Scientology" services in violation of religious trademarks ..
7. Neither I nor any investigator working for me or within my knowledge
photographed inside the Rathbuns' place of business/residence, used any form of electronic
surveillance with respect to the interior of his business/residence, used any form of microphone
to overhear private conversations of plaintiff or her husband inside or on the porch of the place
of business/residence, interfered with or wiretapped the Rathbuns' telephone or internet service,
physically blocked or interfered with the Rathbuns' freedom of movement, or physically touched
or threatened the Rathbuns. No surveillance was conducted by photographing into their
windows or doors. No electronic devices were ever used to track Rathbun or his wife. The only
investigative actions undertaken respecting Rathbun (or his wife) were conducted for the purpose
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of obtaining, information with reference to (a) the identity, habits, conduct, business, occupation,
honesty, integrity, credibility, knowledge, activity, movement, whereabouts, affiliations,
associations, transactions, acts, reputation, or character of Marty Rathbun, (b) the location and
disposition of stolen property; and ( c) securing evidence to be used before a court or for
complaints to appropriate law enforcement pursuant to California Business & Professions Code
section 7521 and section 1702.104 of the Texas Occupations Code.
8. In 2010 I interviewed some former co-workers of Monique Rathbun. The
purpose of the interviews was to acquire information regarding Marty Rathbim, his finances, his
activities, his associations and his mental state. I interviewed Monique's ex-husband for all the
same reasons. Monique Rathbun called me in 2010 after these interviews and indicated she was
available to answer questions. These conversations were all for the purpose of the investigation
of Mark Rathbun for the reasons addressed above.
9. In 2009 through early 2011, Rathbun made many virulent and malicious attacks
against the Scientology religion - of which I am a member. These included appearances in the
electronic media through live interviews, interviews to print reporters and his own blog entries.
Among public assertions by Rathbim, were that the way the religious procedures are utilized in
churches of Scientology were somehow incorrect, and his own claims that he could provide
services to Scientologists in a fashion different from the services the churches offered but
supposedly more true to the religion - assertions that are very offensive to me as a Scientologist,
to CSI and to any Scientologist. And, as noted above, Rathbun was engaged in delivering
Scientology services and counseling at his office/home, for compensation, even though he had
been expelled from the religion and possessed no religious authority to provide Scientology
services to anyone. These actions of altering standard Scientology practice, and the delivery of
4
altered Scientology counseling, is known in the religion as "squitTeling." In Scientology
vernacular, Mark Rathbun was a "squirrel."
10. I was infonned, and I saw for myself, that many church parishioners were upset
over the false and derogatory assertions by Rathbun and were upset that this "squirrel" was
offering a bastardized version of Scientology to former members, and seeking to entice
parishioners to leave the faith with false assertions that his brand of so-called Scientology was
more con-ect than standard Scientology delivered in churches.
11. In March of 2011, I learned that CSI was willing to provide assistance and some
funding for Scientologists who wished to demonstrate against what were perceived as heinous
acts by Rathbun. I met with Mark Warlick and John Allender, both dedicated Scientologists, at
CSI offices in Los Angeles, to discuss the potential details and roles for such a project. We
agreed that we would simultaneously demonstrate at Rathbun' s office and make a documentary
regarding Rathbun, part of which would include footage ofprotestors outside the location where
Rathbun was undertaking his "squirrel" activities, and which he was using for his backdrop for
media interviews. A working title for the documentary was "The Story of a Squin-el," arid it was
planned as both a film and sh01t videos of Rathbun and the protests against him to educate other
Scientologists and the general public that Rathbun was a squirrel. We designed a logo for
"Squirrel Busters" to put on T-shirts for the filming. Mr. Allender, as a producer for the
documentary, filed a fictitious business name statement as "Squirrel Busters Productions" and
registered two potential websites we would use: sqbproductions. com and squirre/busters. org.
Mr. Allender would be a producer and one of the primary voices for the documentary.
12. Starting in April 2011, I coordinated some of the Squin-el Buster's activities in
and around Ingleside-on-the Bay, Texas, where Rathbun's squmel activates were in operation. I
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was present during most of the time the Squinel Busters protested and/or filmed. I briefed any
new volunteers who came to act as "squhrnl busters" on the project about Rathbun's propensities
to violence, and the need to always keep the cameras running when Rathbun was in the vicinity.
We also discussed the necessity not to react to Rathbun' s violence, screaming, and rage and
predicted efforts to incite the squirrel busters to fight with him. We agreed that no matter what
Rathbun did, each person would maintain a totally non-violent form of demonstration. In fact, I
received approval from Mr. Abelson to retain a security guard who stood by during much of the
filming. The hope was that through pointed questions and sincere demonstrations we might
enlighten Rathbun to stop making false and malicious statements about Scientology and
Scientologists, or baning that result, to create a documentary showing his true nature as a
violent, foolish, "squirrel."
13. I hired professional videographers for the project to accompany the Squirrel
Busters in their confrontations with Rathbim and to film the protesting outside of his office.
Professional videographer Batt Pan did most of the filming for the project. For a three-day
period, I hired a local videographer named Bert Leahy to assist Mr. Parr. Mr. Leahy turned out
to be extremely unreliable and incompetent and I info1med him after three days that his services
were no longer needed, and paid him for his time. Leahy called a couple of weeks later asking
for further employment, but I declined to use him again. He apparently was upset at his
termination and contacted Mr. Rathbun. Leahy allegedly gave a statement to Rathbun asse11ing
that I told Lealty the Squinel Buster project was "to make Rathbun's life a living hell." This
assertion is utterly false; I never said that or anything similar to Leahy. After Rathbun publicly
posted an interview with Leahy making this asse1tion, Lealty called me several times and left
messages suggesting he would change his story if I paid him to do so. I viewed these messages
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as an attempt to extort me with tlll'eats unless I paid him . Following these messages, I spoke to
Leahy on the phone, at which time he admitted that I did not make the "make Rathbun's life a
living hell" statement he had asserted and that Rathbun had "put words in his mouth." Leahy
also advised me that Rathbun had said he would "take care of me," paid all of his expenses to
come back to Ingleside-on-the-Bay for the recorded interview, and gave Leahy a personal check
for $300 which Rathbun characterized to Leahy as a "gift" from a lady in Switzerland Rathbun
refused to identify. In that conversation Leahy attempted to exto1t me by offering to change his
story if! paid him $20,000, which I refused.
14. The composition of the Squinel Busters was primarily volunteers who changed
from week to week, as each volunteer had other responsibilities. Mr. Abelson provided some
financial and legal support to the Squirrel Busters from the Church of Scientology International.
15. The Squinel Busters were in Ingleside-on-the-Bay near Rathbun's place of
business from April 18-21, 2011. Jn the month of May 2011, none of the Squin'Cl Busters were
in Texas and no filming was done. On or around June I 0th, filming and protest actions
recommenced from time to time, schedules of the Squirrel Buster volunteers permitting. In
September 2011, all fihning and protests ended. Some of the filming was done in locations far
from Rathbun' s home or office. Rathbun was not present at these other locations. Except for the
few minutes on April 18, 2011 when Messrs. Allender, Warlick and Hirst knocked on Rathbun's
door, all filming was done on public property.
16. Much of this filming was done with one or more of the Squirrel Buster's reading
from signboards with script, and discussing religious issues with the Rathbuns' office/home in
the background. Some of the filming was "B-roll" filming at places Rathbun had claimed to
work, and locations around Texas where he lived or traveled.
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17. CSI covered my expenses for the project, but several of the Squirrel Busters paid
their own travel and food expenses. I rented a house for the Squirrel Busters in the neighborhood
near the filming locations to reduce the costs for lodging, and to increase security.
18. RTC or David Miscavige has never retained me. I have never taken any direction
from, met or communicated with David Miscavige.
Affiant further sayeth naught."
SUBSCRIBED AND SWORN TO BEFORE ME on this I (;.fl.., day of October, 2013,
to celiify which witness my hand and seal of office.
l it) OFFICIAL SEAL I
KERRI PAUTANG
5 " . . NOTARY PUBLIC CALIFORNIA ~
(ij . COMMISSION# 1911945 C
; ,. LOS ANGELES COUNTY -'
! "" MY COMM. EXP. DECEMBER 1, 20141
NOTARYPUBLICIN ~ O R
THE STATE OF CALIFORNIA
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MONIQUE RATHBUN,
Plaintiff,
v.
TECHNOLOGY CENTER,
DAVE LUBOW and ED BRYAN,
Defendants.

207m JUDICIAL DISTRICT
COMAL COUNTY, TEXAS
AFFIDAVIT OF JOHN ALLENDER
On this day, personally appeared John Allender, who, after presenting proper
personal identification and being sworn, upon his oath, stated as follows:
1. My name is John Allender. I am over 18 years of age, have never been
convicted of a felony or crime involving moral turpitude, and am otherwise competent to
make this affidavit. The statements made herein and facts stated in this affidavit arc true
and correct and based upon my own personal knowledge.
2. I am a resident of Santa Clara County, California.
3. I have been an active member of the Scientology religion for over 40 years.
I participated as a religious volunteer on the staff of the Church of Scientology Stevens
Creek in the 1970s for several years, and was the Executive Director of the Church of
Scientology Mission of San Jose for more than 15 years. For many years I have been
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active in defending my religion from persons seeking to attack its precepts and practices
and harassing the members of my faith. For example, I worked extensively to resolve the
attacks by a hate-group calling itself "Anonymous" which made numerous threats to our
churches and members, and promoted hateful "demonstrations" outside our churches. I
worked extensively with an anti-hate network in Santa Clara County, California, the
Office of Human Relations who were investigating the Anonymous group and who
issued a formal letter finding them to be a hate group. I actively pa1ticipate in our
religious activities and outreach in this County and elsewhere in California.
4. I saw Marty Rathbun on CNN in 2010, when he made many false and
hateful statements against my faith, and I was outraged to hear these assertions. I spoke
with Mark Warlick, who was my friend and a staff member at the Los Gatos church and
the Director of Special Affairs for that church and offered to help if there was anything I
could do.
5. In or about March of2011, I received a call from Mr. Warlick, who told me
more about what Rathbun was doing in attacking our religion and its Founder with many
false statements which the media was willingly repeating. I learned that Rathbun, who
was expelled from the Church of Scientology, was promoting himself as an "independent
Scientologist," and claiming that our religious practices were somehow wrong, that he
could do better than the standard church practices in delivering Scientology, and
encouraging Scientologists to leave our faith. I saw some of the public statements and
articles quoting Rathbun in this regard, which I viewed as outrageous. The Scientology
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religion has very precisely defined procedures and Rathbun's assertions were the
equivalent ofreligious heresy, called in Scientology "squirreling." The term means
altering the exact Scientology procedure set forth in works of the religion's Founder, and
in Rathbun's case, pretending it is real Scientology practice. Squirreling is about the
worst thing that one can do in the Scientology religion. Mr. Warlick said he intended to
go to Texas where Rathbun lived and let Rathbun know very directly that church
parishioners knew what Rathbun was doing and we !mew he was a squirrel. I discussed
this with Mr. Warlick and volunteered to help and to speak to Rathbun personally about
his wrongful conduct.
6. Mr. Warlick and I thereafter met with Dave Lubow and a staff member of
the Church of Scientology International at the CS! offices in Los Angeles to discuss
Rathbun. Mr. Lubow informed me he was a private investigator but also a filmmaker,
and had made a documentary about harmful psychiatric drugging of children. We came
up with the name Squirrel Busters and discussed creating a documentary regarding
Rathbun. Mr. Warlick was a professional photographer and videographer and with Dave
Lubow's documentary experience we discussed how this could work to protest Rathbun's
actions and to create a documentaty to help educate other Scientologists and the public in
general that Rathbun was a squirrel and a liar. Mr. Lubow was the director and a
producer and general coordinator. I was to be a producer. We would talk to other
members of our church to undertake protest actions in exercise of our First Amendment
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rights. The CSI staff member told us that CSI would help with some of the expenses
involved to allow us to unde1iake this protest action and make the documentary.
7. I thereafter filed a fictitious business name statement as Squirrel Busters
Productions with the city of Campbell, CA. In June 2011, I also registered two potential
websites we would use sqbproductions.com and squirrelbusters.org. I registered the sites
for 2 years and they have now expired.
8. I thereafter traveled to Ingleside on the Bay, Texas and met with Mark
Warlick, and Richard Hirst (another Scientologist who volunteered for the protest and
documentary project). We discussed what should happen in terms of reacting to Maiiy,
because there was concern that he could be volatile and violent, and determined that no
matter what he did, we would maintain a totally non-violent form of demonstration. I
hoped through pointed questions and demonstrations, but not reacting in kind to anything
Rathbun might say against my religion, to shame him into changing his ways. The goal
was to get him to stop presenting himself as a Scientologist and to recant. To me he was
obviously trying to make some cash over his notoriety and relying on the media to do
that. Religiously, it was very offensive for Rathbun to pretend to practice Scientology
and to denigrate the real practice of Scientology.
9. We also wanted to show who Rathbun really was through videos,
interviews and a documentary - a man who was dishonest, illogical and a "squirrel," and
that the "Squirrel Busters" exercised their rights to protest that squirreling and attacks on
our religion. We hoped to do this by asking questions to Rathbun to get him to reveal his
4
squirreling and his trne nature. We wanted to let him know that we knew what he was
doing. Thus, our first visit was a "tech inspection." In a Church of Scientology, a tech
inspection may be done where it is suspected or apparent that non-standard practices are
being undetiaken by a minister or in a religious course room. In that event, a senior
ecclesiastical person or authority would demand to see if the practices of the offending
church or minister was llue to the "technology of Scientology." Thus, our first visit was
appropriately, a "tech inspection" of Rathbun. On April 18, 2011, with a professional
videographer named Bart Parr, and Scientologists Mark Warlick and Richard Hirst, I
knocked on Rathbun's door with video rolling. When he opened the door, I asked to see
his parishioner folders to see ifhe was correctly applying Scientology procedure, or
"tech." Rathbun told us to get off his property and pushed Richard Hirst. We
immediately did leave his front doorway, again with video rolling. Rathbun followed us
to the street, taking video himself, where he assaulted me and ripped a microphone out of
my camera. This incident was posted by us on the internet on.our squirrel buster
Y ouTube channel, and was also posted by Rathbun on his own Y ouTube channel. This
was the one and only time that the Squirrel Busters went onto Rathbun's property.
10. The composition of the Squirrel Busters was mostly different volunteers
who changed from week to week, as all of us had other work or responsibilities at our
respective homes. The Church of Scientology International provided some financial and
legal support to the Squirrel Busters. The crew included, from time to time, a
professional photographer, and at some point, a security professional who was hired by
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Lubow. These professionals were hired to assist in documenting the events and to protect
the Scientologists from any potential harm.
11. In one incident when I attempted to interview Rathbun on the street in front
of his office/home where he was operating his squirrel practice, he repeatedly sprayed me
and my microphone with a hose. The water ruined the microphone.
12. During the course of our filming activities, the Squirrel Busters had non-
violent verbal encounters with Rathbun and plaintiff in public areas, in the course of
which we discussed, often in heated or argumentative terms, Rathbun's "squirrel" and
anti-Scientology activities. Except for the few minutes on April 18, 2011, when I
knocked ori Rathbun' s door, all the rest of filming was done on public property.
13. Many of our videos were put up on Y outube and I saw a number of videos
taken by Rathbun of our actions, which were also posted by him on the Internet.
14. No member of the Squirrel Busters in my observation or within my
knowledge, ever entered the Rathbuns' place of business/residence, peered into it,
photographed inside of it, used any form of electronic surveillance with respect to it, used
any form of microphone to overhear private conversations of Rathbun or his wife inside
or on the porch of the business/residence or interfered with or wiretapped the Rathbuns'
telephone or internet service, physically blocked or interfered with the Rathbuns'
freedom of movement, or physically touched or threatened the Rathbuns.
15. On June 21, 2011, the City ofingleside passed an ordinance directed at the
Squirrel Busters, requiring us to file for a permit in order to film. W c filed an application
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for a permit, but subsequently withdrew it upon legal advice that the ordinance was
unconstitutional as drafted. A local attorney was located for us by the Church of
Scientology International, Richard W. Rogers, to assist as needed. On our behalf, on July
20, 2011, Mr. Rogers wrote to the County Attorney on the matter and the City thereafter
repealed the Ordinance.
16. On September 20, 2011, our lawyer, Richard Rogers, received a call from a
San Antonio attorney, Christopher Gale, who said he represented Marty Rathbun and
threatened to file a lawsuit. Rogers met with Gale and Rene Rodriguez, another lawyer
representing Rathbun, and told them that his clients' acts were protected by the First
Amendment, as our acts were solely the exercise of our rights to protest and the creation
of a documentary regarding what we saw as important religious issues. Gale requested
that the Squirrel Busters agree to stay 150 yards away from Rathbun's prope1ty. Rogers
told Gale the Squirrel Busters could possibly agree to remain at least 20 feet away from
the property. Informal negotiations continued between Rogers and Gale, but no
agreement was reached and no lawsuit was filed.
17. I have never had any dealings or communications with any RTC staff
members on this subject or any matter relating to Texas, Marty or Monique Rathbun, the
Squirrel Busters or any remotely related matter. I have never met or communicated with
David Miscavige prior to or during the filming of the documentary. I did meet Mr.
Miscavige for the first time at the Grand re-openings of the newly renovated Stevens
Creek and Los Gatos Churches of Scientology in 2012. Mr. Miscavige was present as the
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ecclesiastical leader of the religion at these ceremonies to dedicate the newly opened
church buildings. At each, I literally said a quick hello and shook hands and had my
picture taken to commemorate the events. I was not paid by RTC, directed by RTC or
communicated with RTC on the Squirrel Buster project.
18. I covered my own expenses traveling to and from Texas to my home in
California several times.
JOHN ALLENDER
State of California )
c:.3((,114.. c-te..k.
County of belt Angeles ')
Subscribed and sworn to (or affirmed) before ti<i} IV-J on this
Jj;_dayof&clb}.M ,2013,by ,proved
to me on the basis of satisfactory eviden the person(s) who appeared before me.
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CAUSE NO. C-2013-lUll:.16
MONIQUE RATHBUN,
Plaintiff,
v.
l>A V1D MISCAVIGE, RELIGIOUS
TECHNOLOGY CENTER,
Defendants.

207 JUDICIAL DISTRICT
COMAL COUNTY, TEXAS
AFFIDAVIT OF RICHARD HIRST
On this day, personally appeared Richard Hirst, who, after presenting proper
l. My name is Richard Hirst. I am over 18 years of age, have never been
convicted of a felony or crime involving moral turpitude, and am otherwise competent to
make this affidavit. The statements made herein and facts stated in this affidavit are true
and correct and based upon my own personal knowledge.
2. I am a resident of the State of Florida.
3. I own a small electronics company which manufactures equipment for
various companies, including the aviation industry.
4. I have been an active and devoted Scientologist for 40 years.
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5. In April of2011, I received a call from a staff member of the Church of
Scientology International, telling me that John Allender, Dave Lubow and Mark Warlick
were planning to go to Texas to protest the actions of a man named Marty Rathbun, and
to create a documentary regarding their protest efforts and Rathbun's activities. I had read
about Rathbun and knew that he was a former member of the Church, but that he was
now an apostate of the religion making lurid and false statements about my faith. I agreed
to participate in the project in support of my religious rights.
6. I thereafter paid my own way to fly to Texas. I met with John Allender,
Mark Warlick, and a videographer named Bart Parr near Corpus Christi. Mr. Allender,
Mr. Warlick and Mr. Lubow had already worked out many of the details of the project. It
was to perform protests against Mark Rathbun arising out of his public attacks against the
standard practice of Scientology-- which he denigrated -- in lieu of his own distorted
practice of pseudo-Scientology which he offered. Our second purpose was to create a
documentary of those protests and Rathbun's acts. I considered Rathbun's acts to be to
be an altered form of Scientology, called in our religion, a "squirrel," oftbeat and totally
wrong practice. So we called ourselves "Squirrel Busters."
7. I was in Ingleside-on-the-Bay four different times for several weeks in all. I
participated in the movie making and demonstrations against Mark Rathbun outside of
his office/home where he was undertaking this "squirrel" practice. I felt very strongly
about the religious issues involved in our demonstrations and our right to exercise our
right to protest Rathbun 's wrongful acts.
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8. Often Marty Rathbun ands metimes his wife would come out to the street
where we were staging the movie makin and the protests. I was assaulted by Rathbun
during this process, having been shoved him came up to me
on one occasion and knocked my to stop protesting. However,
despite Rathbun's assaults and battJries, I and my fellow Squirrel Busters felt it important
to maintain a totally peaceful protest, and we did so. On several occasions, Rathbun's
wife, named Monique, came out to talk to us and engaged in debate on religious issues. I
requested that she try to keep her husband under control so we could make our movie and
protest without his intimidation and assault and disruption of our filming.
9. During our protests and movie making, never did I or my fellow Squirrel
Busters film into Rathbun's house, doors or windows. We never blocked the way of Mr.
or Mrs. Rathbun or physically intimidated them in any way.
10. Only once did we go on Rathbun's property-the very first day we arrived.
On that date in mid-April 201 l, we knocked on Rathbun's door to talk to him and asked
to do a "technical inspection" of his notes and materials. This is a Scientology tenn,
meaning to review the procedures of a Scientology minister/auditor. We knew that
Rathbun could not pass a tech inspection because he was a "squirrel" and was not
perfonning standard Scientology procedures. He told us to leave his property, which we
inllllediately did.
11. The subject of the protest was not Monique Rathbun. Rather, the subject
was Marty Rathbun and the primary object was Marty Rathbun's improper application of
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Scientology materials in an offensive manner, pretending what he was doing was actual
Scientology, as well as his false and highly derogatory assertions against my religion.

RICHARD HIRST
SUBSCRIBED AND SWORN TO BEFORE ME on this 15 day of October,
2013, to certify which witness my hand and seal of office.
NOTARY PUBLIC IN AND FOR
THE STATE OF FLORIDA
?<.2.._ (/)<N<-.,' .._,, ./"?'! i-rCN"VO
(Printed Name ofNotary Puhliy)
My Commission Expires: 77 2.o ( 6
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MONIQUE RATHBUN,
Plaintiff,
v.
TECHNOLOGY CENTER,

Defendants.

COMAL COUNTY, TEXAS
AFFIDAVIT OF MONTY DRAKE
On this day, personally appeared Monty Drake, who, after presenting proper personal
identification and being sworn, upon his oath, stated as follows:
1. "My name is Monty Drake. I am over 18 years of age, have never been convicted of a
felony or crime involving moral turpitude, and am otherwise competent to make this affidavit.
The statements made herein and facts stated in this affidavit are true and correct and based upon
my own personal knowledge.
2. I am a resident of Hood County, Texas.
3. I am a private investigator licensed in the states of Texas and Oklahoma, and have been
in the private investigation industry since 1986. My work has been diverse and includes
investigation of third party personal injury cases, workers' compensation and non-subscriber
cases, background checks and investigations for employers and other business entities, witness
and asset location, skip tracing and other general investigations.
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4. One specialty of my work has been investigating violations of intellectual property rights,
production and marketing of counterfeit goods and, particularly, trademark violations. In this
role, I have worked with dozens of major national and international fashion designers and
producers, investigating and coordinating civil and criminal prosecution of violations of their
intellectual property rights. I have been involved in hundreds of cases and many large arrests
and seizures relating to trademark violations. While many of my clients are in California, New
York, France and Italy, my investigations for each have been focused in Texas. I often
coordinate with law enforcement entities to pursue criminal charges against intellectual property
violators, and have frequently assisted law enforcement and prosecutors in arrests and
prosecutions.
5. Another focus of my work has been investigations for the telecom industry relating to the
bulk purchasing and misuse or illegal use of prepaid mobile phones. I have worked for most
major telecommunication phone companies. Many such mobile phones are purchased in the
U.S., and then sent to the Middle East and other foreign countries. Telecommunication
companies lose money from the illegal use. These phones are also susceptible to use by
terrorists or for other illegal activities, since the phones are inexpensive and often used only once
and, therefore, are difficult to trace.
6. I have never been sanctioned or disciplined by the Texas State Board of Private
Investigators and/or the Counsel for Law Enforcement Education and Training ("CLEET") in
Oklahoma.
7. Los Angeles attorney Elliot Abelson retained me in 2009 on behalf of his client, the
Church of Scientology International ("CSI''), to undertake an investigation in support of
litigation, prospective litigation and threatened litigation related to CSI and to investigate
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potential violations of intellectual property rights licensed to CSI relating to the Scientology
religion. My retention arose in part out of public record research and investigation, in which it
was determined that Mark ("Marty") Rathbun (sometimes hereinafter "Rathbun") was potentially
violating trademarks for which CSI is the exclusive licensee. Mr. Abelson hired me on behalf of
his client CSI to investigate the matters addressed above respecting Mark Rathbun, and also to
gather facts which might be applicable to bringing both potential civil and criminal actions
against Mark Rathbun. Rathbun also made public statements on his blog in August 2010,
encouraging Scientologists to steal church records and/or information from CSI or any other
church entity and to bring the stolen materials to him. I was also told that Mark Rathbun had
received property stolen by a staff member of Bridge Publications (the religion's publishing
house) in September 2010. All of these matters were the subject of my investigation.
8. At no time did I, or anyone working under my direction or in coordination with me,
unde1take any unlawful actions, actions exceeding my license as a private investigator, or any
action which otherwise violated the privacy of Mark Rathbun or his wife, Monique Rathbun.
The focus of the investigation was directed at Mark Rathbun and not at Monique Rathbun.
9. The extent of my investigation was lawful surveillance for the reasons noted above. It
consisted of surveillance, photographing, videotaping and static cameras focused on the area
outside the Rathbuns' office/home and publicly visible from the street or other public area. The
static video and photographing were performed from another house in the neighborhood which I
rented for that purpose. The cameras allowed me to observe persons coming and going from the
Rathbuns' office/home premises. Anything the camera could see, a person could also see from
the street. No surveillance was ever done by me, anyone working with me, or within my
knowledge, which was directed inside the Rathbuns' office/home. No surveillance was done by
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photographing into their windows or doors. No electronic eavesdropping or listening devices
were used in our investigation. No electronic tracking devices were used to track Rathbun or his
wife. Neither I, nor anyone working with or for me, ever entered upon the Rathbuns' property.
Neither I, nor anyone working with or for me, ever spoke with or sent anything to Monique
Rathbun or to her place of employment.
I 0. The investigative actions undertaken respecting Rathbun were surveillance and
interviews conducted for the purpose of obtaining information concerning (a) crimes or wrongs
done or threatened against CSI or other churches of Scientology, (b) the identity, habits, conduct,
business, occupation, honesty, integrity, credibility, knowledge, activity, movement,
whereabouts, affiliations, associations, transactions, acts, reputation, or character of Rathbun and
those associated with him, (c) the location, disposition and recovery of misappropriated or stolen
property, or ( d) securing evidence to be used before a court or for complaints to appropriate law
enforcement.
11. Some of my investigation was via the Internet sites which Rathbun publicly used to
communicate his activities and sometimes I or an associate followed Rathbun's car to determine
with whom he was meeting.
12. These sources of information indicated that both Mark Rathbun and his wife were
apparently engaged in business pursuits from their office/home potentially in violation of and
profiting from Scientology trademarks and copyrights, were seeing clients and others at their
office/home who were persons who had evidently left the Church of Scientology, who were
present members of the Church of Scientology and/or were individuals involved in potentially
criminal, tortuous and/or litigation actions against the Church. The Rathbuns were providing
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interviews from their office/home to media members who had been critical of the Church, and
journalists were meeting with them at their office/home.
13. I billed CSI's counsel, Mr. Abelson, for my services.
14. I never had any dealings or communications with any Religious Technology Center
("RTC") staff members or David Miscavige, have never worked for or received funds from RTC,
and have never met or communicated with David Miscavige, either directly or indirectly.
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SUBSCRIBED AND SWORN TO BEFORE ME on this ( - day of October, 2013,
to certify which witness my hand and seal of office.
KELLY JO WILCOX
My Commlulon Expir11
AUQllll 28. 2017
v/t
(Printed ame of Notary Public)
My Commission Expires: O'{, a-8-'{)f>/1
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CAUSE NO. C-20131082B
MONIQUE RATHBUN,
Plaintiff,
v.
DAVID MISCAVIGE, RELIGIOUS
TECHNOLOGY CENTER,
Defendants.


COMAL COUNT'f; TEXAS
AFFIDAVIT OF STEVEN GREGORY SLOAT
I
On this day, personally appeared Steven Gregory Sloat, who, after presenting proper
1. My name is Steven Gregory Sloat. I am over 18 years of age, have never been
convicted of a felony or crime involving moral turpitude, and am otherwise competent to make
this affidavit. The statements made herein and facts stated in this affidavit are true and correct
and based upon my own personal knowledge.
2. I am a resident of Harris County, Texas.
3. In 1976 and 1977, I was a police officer in Houston, Texas. I was recommended
for appointment to the President by Senator John Tower and became a Deputy U.S. Marshal In
1977, which position I held for 11 years, until 1988. In 1989 I became a professional race car
driver through 1996, and still teach racing to younger drivers. I am now an author, having
written and published A Day to Die, and am in the process of a writing a further book.
4. In early 2013, I was retained by J.R. Skaggs, a licensed Texas Private
Investigator because of my investigative and law enforcement background. I was asked to
assist Mr. Skaggs as an undercover contractor in an investigation in Comal County relating to a
former member of the Church of Scientology. But, I had no oral or written communications with
Aftidavil of Steven Gr&gofy Sloat Page 1
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anyone in any Church of Scientology. All of my communications and directions on this matter
were with Mr. Skaggs.
5. I was informed by Mr. Skaggs that the client who retained Mr. Skaggs had
concern regarding a man named Mark ("Marty'') Rathbun, who had recently moved to Bulflerde,
Texas. Mr. Skaggs told me Rathbun was a former Scientologist who was trying to divert people
away from the Church of Scientology. Mr. Skaggs told me that Rathbun was engaged in some
sort of practice similar to Scientology of his own creation at that location and was seeing clients
there. I was to attempt to see who was going to the premises where he was undertaking this
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activity, get pictures if possible of persons associating with him, and to meet Rathbun and to get
to know him and, if possible, so he would tell me more about what his activities were at that
location.
6. I rented a property next to Mr. Rathbun's business/residence in Bulverde, in a
wooded area. I was provided three low resolution cameras in the hopes that a camera could
determine when a car arrived at the parking area of Mr. Rathbun's property adjacent to my
property. These were cameras typically used in deer runs, had a focal length of about 1-20
yards and could not be adjusted. There was no zoom capability. Objects much beyond the
focal length gradually became obscure. The cameras are the type typically used to photograph
game, operating on a motion detector and taking a picture when something moved in front of
the camera, and had the capability of sending the pictures via cell phone to a web site where
the pictures could be seen. The manual for the cameras indicated they were for game purposes.
In addition to the motion detector setting, I set the cameras to take one picture an hour.
7. I placed one camera pointed towards the driveway area next to Rathbun's
premises, one towards the road facing away from his premises to record who was coming onto
the property, and one on a deer stand on the property, facing away from his property.
8. The cameras never pointed directly at Rathbun's office/house. The cameras
each took a picture when the motion detector perceived motion in front of it and was also set to
A l f t d a ~ l of Steven Gregory Sloat Page2
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take one picture per hour. The camera facing Rathbun's premises was 60-70 yards from the
area where a car might be parked. The distance was much too great for the device to detect
motion on his property, and therefore took no pictures caused by motion on his property. The
camera pointed through trees and saplings towards the driveway and shed area. The clJ.mera
pointing towards his property was not useful for the intended purpose, as the resolution was
poor, and the camera had no zoom or focal adjustment capabilities. An example of the scene
viewed from the camera is attached as Exhibit 1. I tried a different location, seen in the picture
of Exhibit 2, but it was equally unworkable.
I
9. There was an old deer stand on the property, where i placed one of the cameras
facing away from Rathbun's property. I left a note on that deer stand with my name and phone
number to attempt to locate who had placed the stand there. Rathbun evidently came onto my
property, as he called me at the number given. I told him I was working on a book I was writing,
had leased the property and intended to bring a camper there in the future to do work in an
undisturbed location. We chatted for about 1 o minutes.
1 O. In early July of 2013, I came onto the property to change the batteries, as I did
occasionally. Rathbun was standing at the edge of my property. I spoke to him briefly. Rathbun
evidently came onto the property a few days later on July 27, 2013, as seen by the motion
detector photo at Exhibit 3. This was the last visible picture from this camera, as he placed tape
over the lens so that pictures could no longer be taken. The cameras were removed a few days
later.
11. I never saw the plaintiff, Monique Rathbun. I never talked to her, never had any
communication with her and never photographed her. The subject of the investigation was not
Monique Rathbun. Rather, the subject was Mark Rathbun and the object was Mark Rathbun's
associations and business dealings.
Affia3.llit o! SI even Gregory Sloat Page3
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SUBSCRIBED AND SWORN TO BEFORE ME on this
to certify which witness my hand and seal of office.
11-IL day of October, 2013,
'
Affidavit of Steven Gregory Sloal
NOTARY PUBLIC IN AND FOR
THE ST A TE OF TEXAS
(J/, (]I Pl<A })_, 11.t-i.< v .\-
I
(Printed Name of Notary Publiq)
My Commission Expires:
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EXHIBIT 1
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EXHIBIT 2
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EXHIBIT 3
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Filed
13 September 4 P6:18
Kathy Faulkner
District Clerk
Comal District
MONIQUE RATHBUN IN THE DISTRICT COURT

v.

TECHNOLOGY CENTER, CHURCH
OF SCIENTOLOGY
GREGORY SLOAT, AND
MONTY DRAKE
207rn JUDICIAL DISTRICT
COMAL COUNTY, TEXAS
PLAINTIFF'S FIRST AMENDED PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
The Plaintiff, Monique Rathbun, brings this action against the Defendants, David
Miscavige, Religious Technology Center ("RTC"), Church of Scientology International
("CS!"), Steven Gregory Sloat, Monty Drake, Dave Lubow a/k/a David J. Labow, and Ed
Bryan, and for causes of action shows the following:
DISCOVERY CONTROL PLAN
l. The Plaintiff intends to conduct discovery under Level 3 of Rule 190 of
the Texas Rules of Civil Procedure.
PARTIES AND SERVICE OF PROCESS
2. Mrs. Rathbun is a resident of Comal County, Texas. David Miscavige has
appeared herein and is being served by serving his counsel of record, Lamont A.
Jefferson, Haynes & Boone, LLP, 112 E. Pecan Street, Suite 1200, San Antonio, Texas
78205-1540. Religious Technology Center has appeared herein and is being served by
serving its counsel of record, Lamont A. Jefferson, Haynes & Boone, LLP, 112 E. Pecan
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Street, Suite 1200, San Antonio, Texas 78205-1540. Church of Scientology International
has appeared herein and is being served by serving its counsel of record, Les J. Strieber
III, Davis, Cedillo & Mendoza, McCombs Plaza, Suite 500, 755 E. Mulbeny Ave., San
Antonio, Texas 78212. Steven Gregory Sloat is an individual residing in Houston
(Bellaire), Texas. He may be served by serving him at 4907 Beech Street, Bellaire, Texas
7740 I. Monty Drake is an individual residing in Granbury, Hood County, Texas. He
may be served by serving him at 1620 Malibu Bay Ct., Granbury, Texas 76048.
3. Dave Lubow a/k/a David J. Labow, is a California resident doing business
in Texas. He may be served with process and this pleading by serving the Secretary of
State of Texas at 1019 Brazos Street, Austin, Texas 78701, as its agent for service. A
copy of same may be mailed to Dave Lubow a/k/a David J. Labow at 26501 Torrey
Pines, Newhall, Santa Clarita, CA 91321-2235.
4. Ed Bryan is a California resident doing business in Texas. He may be
served with process and this pleading by serving the Secretary of State of Texas at 1019
Brazos Street, Austin, Texas 78701, as its agent for service. A copy of same may be
mailed to Ed Bryan at 2808 N. Naomi Street, Burbank, CA 91504-2023.
SUBJECT MATTER JURISDICTION
5. This action is a suit for injunctive relief and damages in an amount within
the jurisdictional limits of this Court. The Plaintiff seeks monetary relief over $1,000,000.
PERSONAL JURISDICTION
6. Mr. Miscavige, RTC, CSJ, Mr. Labow, and Mr. Bryan are subject to
personal jurisdiction in Texas. Texas comis have general jurisdiction over Mr.
Miscavige, RTC, CSJ, Mr. Labow and Mr. Bryan because they have a substantial
First Amended Petition
Page2
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connection with Texas due to their continuing and systematic contacts purposefully
directed toward Texas. Also, Texas courts have specific jurisdiction over these
Defendants because they have a substantial connection with Texas due to the fact that this
cause of action arises out of or relates to their contacts with Texas. Mr. Sloat and Mr.
Drake are citizens and residents of Texas, where they do business
VENUE
7. Comal County is a county of proper venue, because it is a county in which
a substantial part of the events or omissions giving rise to the claim occurred and are still
occurring.
FACTS
8. Monique Rathbun (fo1merly, Monique Carle) was 33 years old in 2005,
when she met and fell in love with her future husband, Mark Rathbun. Eventually, Mr.
and Mrs. Rathbun made their home in Ingleside On The Bay, Texas, and they were wed
on July 3, 20 l 0. Although this case involves Scientology, Mrs. Rathbun is not, nor has
she ever been, a member of the Church of Scientology. The Church of Scientology is a
notorious, multi-billion dollar cult.
9. Mrs. Rathbun learned at the outset of her romance with Mr. Rathbun that
he was a fmmer member of the Church of Scientology. In fact, Mr. Rathbun had devoted
27 years of his life to the service of Scientology. He was the second highest ranking
official in Scientology's hierarchy. Mr. Rathbun worked directly with David Miscavige,
Scientology's supreme leader. Mr. Miscavige, who refers to himself as the "Pope of
Scientology," wields absolute control over all Scientology corporate operations,
including the operation made the basis of this suit.
Plaintiff's First A1nendcd Petition
Page 3
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10. By 2004, Mr. Rathbun realized that he could no longer abide Mr.
Miscavige's illegal and immoral misconduct, especially Miscavige's physical and mental
abuse of devoted Scientology clergy. Mr. Rathbun escaped from Scientology's secretive,
secure compound in the California desert, and made his way to South Texas, where he
lived in anonymity. Mr. Rathbun's disappearance from his life in Scientology was so
effective that he was rumored to be dead. In fact, it was rep01ted in Wikipedia that he had
died of cancer. Duling those quiet years, Mr. and Mrs. Rathbun met, married, and began
their new life on the Texas coast.
11. Mr. Rathbun was living in relative seclusion in Texas. He had no contact
with his family and friends, who remained in Scientology and who were prohibited by the
Church of Scientology from having any communication or connection with him. There is
a department within the Church of Scientology dedicated to full-scale attack against
anyone who questions or criticizes Mr. Miscavige's reign over the Scientology
corporations. That organization is called the Office of Special Affairs ("OSA"). OSA
employs a cadre of lawyers, investigators, public relations personnel, and shady
operatives to destroy anyone identified as an attacker of Scientology. For several years,
Mr. Rathbun kept quiet and avoided the attention of OSA.
12. In 2009, Mr. Rathbun exercised his rights under the Texas and United
States Constitutions to speak out against Mr. Miscavige's criminal mistreatment of
Scientology clergy. The Plaintiff, Monique Rathbun, did not join her husband in speaking
out concerning Scientology issues, nor has she ever taken a public position regarding
Scientology. Her few public comments have related to the ongoing harassments against
her husband and her. Mrs. Rathbun was never a member of the Church of Scientology.
Plaintiff's First Amended Petition
Page 4
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In no way was she an "attacker" of Scientology. Her only involvement was her marriage
to a prominent former Scientologist.
13. Nevertheless, Mrs. Rathbun has been intentionally targeted by OSA
merely because of her relationship with Mr. Rathbun. Under Scientology's written
policies and procedures, it is "fair game" to threaten that which an enemy seeks to
protect. To Scientology, Mr. Rathbun is an enemy, and his beloved wife is "that which he
seeks to protect." Accordingly, OSA and its co-defendants have engaged in three years
of ruthlessly aggressive misconduct against Mrs. Rathbun. This abusive campaign
continued, unabated, as of the filing of this suit.
14. The Defendants have worked around the clock for t!nee years to destroy
Mrs. Rathbun. She has been harassed, insulted, surveilled, photographed, videotaped,
defamed, and humiliated to such a degree as to shock the conscience of any decent, law-
abiding person. She has been subjected to numerous, aggressive attempts to intimidate
her. Each and all of the Defendants have pa1ticipated enthusiastically in this abuse,
without regard to Mrs. Rathbun's basic rights as a human being. She has been targeted at
home, at work, and anywhere else that she happens to be.
15. As a direct result of the Defendants' relentless campaign, Mrs. Rathbun
and her husband were driven from their cherished home in Ingleside On The Bay. They
moved to a more secluded residence in Comal County in the hope of obtaining the
ordinary privacy and tranquility to which they are entitled. Unfortunately, their respite
was sh01t-lived. The Defendants have resumed their activities against Mrs. Rathbun in
Comal County. Mrs. Rathbun believes that she has no choice but to bring this suit to end
the Defendants' assault upon her privacy, her tranquility and peace of mind, her right to
Plaintiffs First A1nended Petition
Page 5
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work, and her right to freely associate with friends and co-workers free from intrusion,
surveillance, harassment, and embarrassment.
ADDITIONAL JURISDICTIONAL FACTS
16. David Miscavige and RTC have complained that the Plaintiffs Original
Petition failed to plead specific facts to supp01t personal jurisdiction over them in Texas.
Plaintiff disagrees, but in an abundance of caution, the following additional factual
allegations are provided.
17. This case arises from a planned, calculated, multi year operation of
Scientology's Office of Special Affairs ("OSA") in Texas. To the profound suffering of
Mrs. Rathbun, she has been the innocent victim of OSA's primary function -- the
destruction of anyone deemed an enemy of David Miscavige and/or Scientology. David
Miscavige is the absolute, unquestioned authority in Scientology's corporate activities,
and he decides who is an enemy to be attacked.
18. Although it is ostensibly an office within the Church of Scientology
International, OSA reports directly to David Miscavige at RTC. Mr. Miscavige's personal
obsession is the "handling" of Scientology defectors, termed "Squin-els" or "Suppressive
Persons". The more significant the defecting Scientologist, the more obsessive is Mr.
Miscavige's response.
19. No defector from the Church of Scientology is more prominent than Mr.
Rathbun, which explains OSA's "scorched-earth" campaign against him, and its
willingness to attack even his innocent wife. Mr. Miscavige was particularly concerned
about Mr. Rathbun, because of their close, long-term working relationship.
Plaintiffs First Amended Petition
Page 6
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20. In 2004, Mr. Rathbun escaped on a motorcycle from Scientology's
secretive desert compound in California. The level of violence and human rights abuses
committed by, and at the direction of, Mr. Miscavige had risen dangerously. Mr. Rathbun
fled to Texas where he lived quietly, away from the attention of Mr. Miscavige and his
OSA thugs. It was during this peaceful interlude that the Rathbuns began their
relationship.
21. In 2009, Mr. Rathbun broke his silence and spoke to the national media
about Mr. Miscavige's shocking culture of violence in Scientology's desert compound. In
the eyes of Mr. Miscavige, Mr. Rathbun became his primary enemy. It was for such
enemies that Mr. Miscavige created the Office of Special Affairs.
22. Mr. Miscavige is the one and only person in the Church of Scientology
who may authorize a destructive OSA campaign, such as the one undertaken against the
Rathbuns. Thus, according to the routine, consistent, decades-long practice of the
Scientology organizations, Mr. Miscavige authorized OSA's campaign against the
Rathbuns. Consistent with Mr. Miscavige's longtime, established habit, he personally
monitored and micromanaged OSA's operations against the Rathbuns.
23. In 2009, Linda Hamel, the head of OSA, dispatched OSA's top agents to
Texas. Paul Manick and Greg Arnold were pulled off of their decades-long surveillance
of former Scientology leader, Pat Broeker, and sent to Ingleside On The Bay, Texas to
plan a sophisticated surveillance operation against the Rathbuns. OSA already had a
Texas agent, Monty Drake, in place, but Marrick and Arnold were needed because of
their superior skills.
Plaintiff's First Arnended Petition
Page 7
(
24. Mr. Miscavige, RTC, and OSA had employed Monty Drake in Texas
since the l 990's. Mr. Miscavige was well aware of Monty Drake, whose name Mr.
Miscavige thought was humorous, and whose investigative reports were handed to Mr.
Miscavige for his personal attention.
25. Mr. Marrick and Mr. Arnold carried out their Texas assignment for OSA.
They regularly reported by telephone to Ms. Hamel during their work in Texas. They also
submitted a written report to Ms. Hamel. The report detailed their observations,
evaluation, and recommendations for the OSA operation against the Rathbuns in
Ingleside On The Bay. Over their long career with OSA and RTC, Ms. Hamel passed
information and reports from Marrick and Arnold directly to Mr. Miscavige, code named
"The Duke".
26. Later, after OSA's outrageous "Squirrel Busters" operation against the
Rathbuns became notorious in the media, Ms. Hamel, the head of OSA who reports
directly to Mr. Miscavige, replied that "we" sent the Squirrel Busters to Texas to "make
Marty implode."
27. On or about May 25, 2010, Warren McShane, President ofRTC, made a
repmt to the Sheriff of Riverside County, California concerning a recent Scientology
Defector. Mr. McShane reported to the Sheriff, as follows:
"Mr. McShane ... began to suspect that [the defector] would attempt to
meet up with Marty Rathbun, who was described to me as a former church
member, and now Church of Scientology antagonist. Mr. McShane told
me RTC had previously contracted with a private security firm in the State
of Texas to monitor Mr. Rathbun's activities. Mr. McShane contacted the
security firm and provided them with (the defector's] photo and
information and asked that he (McShane) be contacted in the event [the
defector was seen meeting with Mr. Rathbun. According to Mr. McShane,
[the defector] was spotted by the security detail on April 24, 2010 meeting
with Mr. Rathbun at a restaurant in the City oflngleside, Texas."
Plaintiffs First A1nended Petition
Page 8
(
"Mr. McShane summoned (4) church members/employees who know [the
defector] the best and sent them to Texas to attempt to contact him and
perhaps persuade him to return to the facility in Hemet, CA."
Mr. Miscavige has often said that the only reason he keeps Mr. McShane in his position
at RTC is that Mr. Mcshane is "an unusually good liar." Presumably, however, Mr.
McShane had no reason to lie to the Riverside, California Sheriffs Office about RTC's
ongoing activities in Texas.
28. The Squirrel Busters operation against the Rathbuns is an important basis
of this lawsuit. Ed Bryan was sent by OSA from California to join the Squirrel Busters in
Texas. On July 13, 2011, Mr. Bryan wrote the following concerning the Church's Texas
operation against the Rathbuns:
'This is in co-ordination with OSA Int. [Office of Special Affairs -
Church of Scientology International]. They are calling the shots and quite
frankly I don't think it is very effective. The reporters came to our house
the other day and we didn't tell them very much. Our main guy went back
to discuss with them a different strategy. The rat [Rathbun] is getting more
brazen and yesterday I actually had a I minute comm cycle [conversation]
with rum while he was on a walk. The guy is nuttier than a fruitcake. He's
gone off the deep end. Taking him down will be no easy task. I just hope
he self destructs before he does more damage to our church. He has gotten
to some OTVIII's and I just can't think with how stupid they are to actually
believe what he is saying." Bracketed information added.
29. Another Squirrel Buster from California was Joanne Wheaton. While she
was in Texas, hounding the Rathbuns, she received regular written instructions from
OSA, micromanaging the Squirrel Busters' activities. No detail was too trivial to escape
the attention of Mr. Miscavige's agents, as exemplified by the following excerpts from an
email to her, dated September 3, 2011:
Page9
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"You should brief the SQBs [Squirrel Busters] on the following:
"A couple of points need to be handled. The SQBs still look downstat
[derogatory term among Scientologists]. They went out without their shirts
tucked in and it looks unprofessional on camera. The badges also look
tacky. These points still need to be upgraded I corrected.
"He [Rathbun] is much more enturbulated [Scientology term for a
disturbed state of mind] when people ignore him and go right on telling
him that he is not a Scientologist, that he is a suppressive person, that we
love and totally support COB [David Miscavige] and all he is doing for
Scientology, that Rathbun is a complete disgrace, is an insane psychotic
squirrel whose entire purpose is to destroy the tech. He is anti-Scientology
as all his actions show.
"That's the viewpoint they need to have. We love COB [David Miscavige]
and hate SP squirrels like you.
"People who are to deal with Rathbun need to read some references and
drill. They are not to engage in any more discussions with him."
Bracketed iliformation added.
30. Bert Leahy, a non-scientologist videographer from Dallas, Texas, was
hired under false pretenses by the Squirrel Busters to join them in Ingleside On The Bay.
Mr. Leahy then learned the true nature of the job from an unsavory character operating
under the false name of "Dave Stater". In actuality, Mr. Stater was Dave Lubow, a
California private investigator, who has performed "dirty tricks" operations for Mr.
Miscavige, RTC, and OSA for more than 30 years. Mr. Lubow's unscrupulous nature is
prized by Mr. Miscavige. Mr. Lubow told Mr. Leahy in no unce1tain terms:
"Our goal is to make Marty's life a living hell ... with every means
possible of impeding his everyday living, and make it so miserable for him
and his neighbors that his neighbors will want him to move."
Plaintiffs First An1cndcd Petition
Page 10
(
The virulence of the Squirrel Busters was also directed against Mrs. Rathbun.
Joanne Wheaton told Mr. Leahy that Mrs. Rathbun "made her blood boil" and
that she "couldn't stand the sight of her [Mrs. Rathbun]."
31. Mr. Leahy soon sickened of his participation in the Squirrel
Busters' Texas operation against the Rathbuns. But, before he quit, he observed
that the Squirrel Busters seemed to have an unlimited budget, and its leaders
received instructions and made reports by cell phone to Los Angeles. OSA's
headquarters are located in a Los Angeles Scientology building, along with
offices of Mr. Miscavige and RTC.
32. On July 20, 2011, the attorney for Squirrel Busters Productions,
Richard W. Rogers, Ill, of Corpus Christi, Texas wrote to the County Attorney of
San Patricio County, where the Squirrel Busters' operation against the Rathbuns
was ongoing. The letter is unremarkable, except for the fact that it was cc'd to
Allan Cartwright, OSA's Director of Legal Affairs. Mr. Cartwright answers to Mr.
Miscavige at RTC.
33. The official spokesperson for the Church of Scientology, Karin
Pouw, has written:
"I further wish to point out that the Church has put out videos which show
Rathbun lying in his own words, based on his own statements. To that end
I further invite you to watch the video at this link showing Rathbun' s
nature: http://www. whoismartyrathbun .com/."
The video footage in question was the Squirrel Busters' video recording of the Rathbuns
in Texas. Previously, the Church denied any connection to the Squirrel Busters.
Furthermore, the referenced website is one of approximately 35 "hate sites" established
by the Church to attack Mr. and Mrs. Rathbun.
Page 11
34. Texas private investigator, Monty Drake, whose name Mr. Miscavige
found to be so amusing, carried out many of the Defendants' operations against the
Rathbuns. Of significance, he entered into two 3-year leases of a house across the street
from the Rathbuns' home in Ingleside On The Bay, Texas. Mr. Drake installed in the
leased house an array of high-powered surveillance video and still cameras aimed at and
into the Rathbuns' home. The cameras were connected to a computer system that stored
and transmitted the Rathbuns' images to California to satisfy Mr. Miscavige's obsessive
interest.
35. None of the Defendants' tortious activities in Texas, which continued
until this Court's Temporary Restraining Order was issued, could have been perfmmed
without authorization by David Miscavige, who is the head of RTC and the unquestioned
ruler of all Scientology organizations. No one else in any Scientology organization has
the authority to approve such an operation. Furthermore, any and all of these unlawful
activities in Texas could have been stopped instantly by a single word from Mr.
Miscavige. Mr. Miscavige approved and ratified these activities. Official and unofficial
Church spokespersons and publications have vilified and attacked the Rathbuns
throughout their ordeal. Church funds have financed the Rathbun campaign in Texas, and
Church personnel have staffed it.
36. Mr. Miscavige may have been careful to keep his body outside of Texas,
but he personally directed several OSA operations in Texas before the Rathbun operation.
Established principles of fair play and substantial justice dictate that he should be made to
answer these allegations concerning his deliberate, tmtious activities against Texas
citizens in a Texas comtroom, before a Texas jury.
Page 12
CAUSES OF ACTION
37. Intentional Infliction of Emotional Distress. The Defendants'
misconduct, as described above, constitutes intentional infliction of emotional distress,
for which Mrs. Rathbun hereby sues. The Defendants acted intentionally or recklessly,
and Mrs. Rathbun has suffered, and is suffering, severe emotional distress. The
Defendants' misconduct is extreme and outrageous, and proximately caused Mrs.
Rathbun's emotional distress. No alternative cause of action would provide a remedy for
the severe emotional distress caused by the Defendants' misconduct.
38. Tortious Interference With Contract. The Defendants' misconduct, as
described above, constitutes t01tious interference with contract, for which Mrs. Rathbun
hereby sues. Mrs. Rathbun has had a valid contract of employment with her employer.
The Defendants have willfully and intentionally interfered with the contract. The
Defendants' interference has proximately caused injury to Mrs. Rathbun, and she has
incurred actual damages or loss.
39. Invasion of Privacy - Intrusion on Seclusion. The Defendants'
misconduct, as described above, constitutes invasion of privacy by intrusion on seclusion,
for which Mrs. Rathbun hereby sues. The Defendants intentionally intruded on Mrs.
Rathbun's solitude, seclusion, or private affairs. Such intrusion would be highly offensive
to a reasonable person. Mrs. Rathbun suffered injury as a result of the Defendants'
intrusion.
40. Invasion of Privacy - Public Disclosure of Private Facts. The
Defendants' misconduct, as described above, constitutes invasion of privacy by public
disclosure of private facts, for which Mrs. Rathbun hereby sues. The Defendants
Page 13
publicized information about Mrs. Rathbun's private life, which would be highly
offensive to a reasonable person, and which is not of legitimate public concern. Mrs.
Rathbun has suffered injury as a result of the Defendants' disclosure.
INJUNCTIVE RELIEF
41. Mrs. Rathbun is entitled to a Temporary Restraining Order, Temporary
Injunction, and Permanent Injunction prohibiting the Defendants from interfering with
her employment, from invading her privacy, and from inflicting emotional distress upon
her. There is substantial risk of imminent harm and irreparable injury to Mrs. Rathbun.
Her damages, by their nature cannot be measured by any certain pecuniary standard. She
seeks ex pa1te consideration of this request for Temporary Restraining Order to prevent
further irreparable injury and to preserve the stains quo pending a hearing on her request
for Temporary Iajunction and final trial.
DAMAGES
42. Actual Damages. As a direct result of the Defendants' unlawful conduct,
Mrs. Rathbun has suffered and will continue to suffer recoverable actual damages within
the jurisdictional limits of this Court, including but not limited to, mental anguish
damages, loss of earning capacity, damage to reputation, and financial loss.
43. Exemplary Damages. The Defendants' unlawful conduct was of such a
degree and character as to make them liable for exemplary damages within the
jurisdictional limits of this Court.
VICARIOUS LIABILITY
44. The Defendants' misconduct, as described above, makes them liable for
each other's actions and the actions of their employees and agents under theories of
Page 14
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assisting or encouraging, assisting and paiiicipating, concert of action, conspiracy,
agency, partnership, joint enterprise, piercing the corporate veil, and respondeat superior.
AMENDMENT AND JOINDER
45. Mrs. Rathbun expressly reserves the right to amend her pleadings and to
join additional parties, as needed.
REOUEST FOR DISCLOSURE
46. The Plaintiff requests that the Defendants disclose, pursuant to Texas Rule of
Civil Procedure 194, the information or material described in Rule I 94.2(a)-(I).
PRAYER
WHEREFORE, PREMISES CONSIDERED, the Plaintiff prays that upon trial
hereof, she be awarded judgment against the Defendants for injunctive relief, actual
dainages, exemplaiy damages, court costs, pre-judgment interest, post-judgment interest,
and such other and further relief to which she may be justly entitled at law or in equity.
Respectfully submitted,
JEFFREY & MITCHEL.hi\ C.
/
ByJ:
Ray Jeffr
State Bar Number 10613700
A. Dannette Mitchell
State Bar Number 24039061
2631 Bulverde Road, Suite 105
Bulverde, TX 78163
(830) 438-8935
(830) 438-4958 (Facsimile)
rjcffrcy!<V.sjmlawvcrs.com
d rn itchcl I laJ,sjm lawvcrs. com
Page 15
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(
THE WIEGAND LAW m ~ t , P.C.
Marc F. Wiegand
State Bar No. 21431300
434 N. Loop 1604 West, Suite 2201
San Antonio, Texas 78232
(210) 998-3289
marc0\wiega11dlawfirm.com
PULMAN CAPPUCCIO PULLEN & BENSON, LLP
Elliott S. Cappuccio
State Bar No. 24008419
2161 N.W. Military Hwy., #400
(210) 222-9494
(210) 892-1610 (Facsimile)
ecappuccio@.puln1anlaw.com
ATTORJ'IEYS FOR MONIQUE RATHBUN
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document has been
forward viafi1csimile to the following counsel of record in this cause in accordance with
the Texas Rules of Civil Procedure on this the _!/lb_ day of September, 2013:
Lamont A. Jefferson
Haynes & Boone, LLP
112 E. Pecan Street, Suite 1200
San Antonio, Texas 78205-1540
J. Iris Gibson
Haynes & Boone, LLP
600 Congress Ave., Suite 1300
Austin, Texas 7870 l
Les J. Strieber Ill
Davis Cedillo & Mendoza, Inc.
McCombs Plaza, Suite 500
755 E. Mulberry Avenue
Via Facsimile (210) 554-0413
Plaintifl"'s First An1ended Petition
Page 16
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CAUSE NO.--------
MONIQUE RATHBUN

v.

OF SCIENTOLOGY
INTERt'<ATIONAL, STEVEN
GREGORY SLOAT, AND
MONTY DRAKE
___ JUDICIAL DISTRICT
COlVIAL COUNTY, TEXAS
AFFIDAVIT OF MONIQUE RATHBUN
Before me, the undersigned notary, on this day personally appeared Monique Rathbun,
the affiant, a person whose identity is known to me. After I administered an oath, affiant
testified:
I. "My name is Monique Rathbun. I am over 18 years of age, of sound mind, and
capable of making this affidavit. The facts stated in this affidavit are within my personal
knowledge and are true and correct.
2. I am married to Mark Rathbun, a prominent former Scientologist. For several
years, we led a quiet, rewarding life together on the Texas coast before the Defendants started
their campaign of harassment and intimidation against us.
3. In 2009, my husband broke his silence about Scientology. He gave national media
interviews about physical and mental abuse he witnessed at Scientology's headquarters in
California. I have never been a Scientologist. I gave no interviews, nor did I speak out publicly
concerning these matters.
4. Within a week of my husband's first media interviews, we were both put under
surveillance by Scientology operatives. We have now been living under this constant
surveillance and harassment for four years.
Affidavit of Monique Rathbun
Page 1
I
'
5. On several occasions when my husband travelled out of town, Scientologists
appeared at our home after dark to interrogate me aggressively. These unwelcome visitors
refused to give their names. Although I tried to be strong, this was frightening to me as a woman
at home alone. When I would try to call the police, the Scientologists would flee.
6. Anonymous callers phoned our home and threatened us. Scientology operatives
openly followed me as I drove to and from work.
7. In 2011, the Scientology operatives leased a five bedroom home less than 200
yards from our residence. This outpost was occupied by at least five Scientology operatives
whose full-time job was to make our lives a living hell, as one of them has publicly admitted.
They usually wore shirts identifying themselves as Scientologists.
8. We couldn't even peacefully take our evening walk with our little dog, Chiquita.
The Scientology operatives used electronic surveillance to alert them whenever we left our
home. Within minutes of beginning our walk, the Scientology agents would approach us in a
golf cart with up to six cameras trained on us as they hurled insults and rude questions relating to
Scientology.
9. If we left home by car, we were inevitably followed by Scientology operatives
and tailed to wherever we went. We were then publicly assaulted and harassed wherever we
went, including restaurants and the beach. The Scientology agents harassed us in this fashion
for 199 days straight. Our neighbors and local government tried to help us, but the harassment
continued.
10. From 2010, to the present, the Scientologists have targeted me specifically for
harassment. They have worked to drive a wedge between me and my husband, family, and co-
workers. Scientology investigators have visited my mother, my father, my former husband, my
Page 2
friends, and my co-workers. The investigators have falsely claimed to all of these contacts that
my life is at risk as long as I remain with my husband. These malicious allegations are hateful
and distressing.
11. Presumably because I am a woman, the Defendants seem obsessed with my
sexuality. They sent a sex toy to me at my workplace, which was very embarrassing. With their
constant surveillance of me, they knew when I was away from the office, at which time they sent
flowers to one of my female co-workers with a "romantic" message purporting to be from me.
Of course, this was distressing to me.
12. Scientology websites have published bizarre and sometimes vile allegations
against me, including false claims that I am a sexual pervert. They have even alleged that I am
not even a woman, but a man who has had a secret sex-change operation. So, I have even had
my womanhood questioned as part of this sick campaign to inflict maximum emotional distress
on me.
13. Near the end of2012, we discovered that Scientology private investigator, Monty
Drake of Granbury Texas, had leased for three years a residence across the street from our home
in Ingleside On The Bay. Behind the residence's blinds, peaking through small cut-outs, was an
array of high-powered still and video cameras pointed at, and into, our home.
14. Although we truly loved our home and our neighborhood on the Texas coast, I
could no longer take the constant harassment and lack of privacy. Although it cost us the loss of
$35,000 in lease/purchase equity, we moved to find refuge from the Defendants' harassment.
After extensive searching, we found what we believed was an acceptable home with sufficient
seclusion in Comal County, Texas.
Page 3
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15. Unfortunately, despite our new home's apparent privacy, some or all of the
Defendants continued to watch our comings and goings from a distance, and to follow us when
we drove from home. Since July of2013, the Defendants' activities against us have intensified.
They have leased undeveloped property adjacent to our homestead and installed surveillance
cameras directed at our property. Defendant Sloat has made contact with us under a false identity
and has provided preposterous, false stories to explain the surveillance cameras and why he is
moving an RV onto this undeveloped property.
16. I am a private person by nature. The continuous and aggressive invasion
of privacy to which f have been subjected, and the related personal and psychological abuse, has,
and continues to be, a cause of great distress to me. It has cost me my privacy, my peace of
mind, and I believe it is calculated to damage my relationship with my husband, and his
relationship with my family and friends so as to injure me. Because I have been subjected to
harassment that is habitual, sadistic and categorical, l also live in fear that the Defendants will
resume their efforts to discredit me with my co-workers, employer, family and friends."
'Further affiant sayeth not."

Momque Rathbun
STATE OF TEXAS

COUNTY OF COMAL
SUBSCRIBED AND SWORN TO BEFORE ME, by the said Monique Rathbun, on this
the .lJ..,___ day of August, 2013, to certify which witness my hand and seal of office.
\\\>llltF
CHRISTINE A. THOMPSON
Notary Public, State of Texas
% .. }.. My Commission Expires
Ap11122, 2014
Page 4
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(
CAUSE NO. C2013-1082B
MONIQUE RATHBUN

~

OF SCIENTOLOGY
GREGORY SLOAT, AND
MONTY DRAKE
207rn JUDICIAL DISTRICT
COMAL COUNTY, TEXAS
AFFIDAVIT OF MARK RATHBUN
"My name is Mark Rathbun. I am also known as Marty Rathbun. I am over the age of
eighteen (18) years, of sound mind, and otherwise capable of making this affidavit. I have
personal knowledge of the facts and statements contained herein, and all are true and correct."
I. "I served with Mr. Miscavige in Scientology's Sea Organization for 27 years. From 1982
to 2004, I answered directly to Mr. Miscavige. As Inspector General of Religious Technology
Center ("RTC"), I was Mr. Miscavige's second in command. Mr. Miscavige and I were the only
Scientologists ever awarded Scientology's "Medal of Honor" by its founder, L. Ron Hubbard. In
the history of Scientology, no other Church executive worked with Mr. Miscavige more closely,
for a longer period of time, than I did.
2. 'The complex network of Scientology organizations is run by a shadow organization
known as the Sea Organization, or Sea Org. It is so named because it was formed originally by
Scientology founder, L. Ron Hubbard, in I 967 aboard a ship sailing the Mediterranean Sea. The
Sea Org is a paramilitary hierarchy. Each Sea Org member holds a naval rank, from Swamper
(initiate) to Commodore, the title held by L. Ron Hubbard during his life. Sea Org members vow
by contract to serve for a billion years. The Sea Org was organized from the beginning by
Hubbard to be amorphous and mobile so as to evade criminal or civil liabilities. The Sea Org
was Hubbard's ultimate answer to his own description of the philosophic bases for Scientology
organizations' legal structure:
'If anybody tried to attack a Scientology organization and pick it up and move it
out of the perimeter or go over the hills with it today- this happened to us once -
why, they would find themselves involved in the most confounded weird mass of
legal - well, it is just like quicksand. Quicksand lt 's an interesting trick Every
time they shoot at you on the right side of the horse, you 're on the lej/ side of the
horse; and then they prove conclusively you 're on the left side of the horse, you
prove conclusively that you 're on the right side of the horse. They go mad after a
while. This is what the basic legal structure is. '
Affidavit of Mark Rathbun
Pagel
3. "Since the 1967 formation of the controlling, yet amorphous Sea Org, the corporate
structures of Scientology have come and gone, and changed and refotmed, many times. The
only significant factor that has remained constant through Scientology's many corporate
transformations is that the highest ranking Sea Org member is in complete control.
4. "Until Hubbard's death in January of 1986, that controlling leader was Hubbard himself,
the Commodore of the Sea Org. Since Hubbard's death, that controlling leader has been David
Miscavige. Miscavige has held complete control of all Scientology organizations as the highest
ranking Sea Org officer. Since Hubbard's death, Miscavige has been the Sea Org's only Captain,
and no one holds a higher rank. Over the years, Miscavige has temporarily bestowed a number
of brevet (temporary) Captain ranks to other senior Sea Org members. He has done so, as he
explained to me, for the purpose of obscuring his own unquestioned control of all of Scientology
as its Sea Org Captain. For several years, I carried the temporary rank of brevet Captain, but
Miscavige retained absolute control as the only permanent Captain of the Sea Org.
5. "Until his death, Hubbard controlled all of Scientology. The Scientology organizations
shielded him from civil and criminal liabilities by maintaining the fiction that he was merely the
"Founder of Scientology." His position was described as an arm's length, passive, semi-retired
position uninvolved with the management of Scientology operations. All the while, the
thousands of Sea Org personnel answered to him as their all-powerful commander. Directions
from Sea Org conunand took precedence over all of the corporate charters, bylaws, and articles
of incorporation of the myriad Scientology corporations staffed by Sea Org management.
6. "In 1981, I was recruited by Mr. Miscavige from my position in the personal office of L.
Ron Hubbard to join a critical Sea Org mission. Mr. Hubbard had been driven into seclusion by
federal prosecutors and civil litigants who were making a determined effort to pierce the
Scientology corporate veil in order to indict and sue Mr. Hubbard as the effective head of all
Scientology operations.
7. "Mr. Hubbard's wife, Mary Sue Hubbard, and ten other high-level Sea Org members
were convicted in federal court for obstruction of justice. They were members of Scientology's
Guardians Office. The Guardians Office had carried out the largest domestic infiltration of the
United States Government in American history, and these co-conspirators went to federal prison.
Due to the Guardians Office scandal, Hubbard directed Miscavige to accomplish three major
aims: (1) re-create an intelligence, PR and legal network to replace the disgraced Guardians
Office in a way that would protect Scientology's spying and harassment operations by using
buffer corporations and new levels of security; (2) by any means necessary, end the multitude of
criminal and civil threats pending against Hubbard and Scientology; and (3) create a new
cotporate structure that would allow the Sea Org to operate as it always had, but with legal
buffers in place that would prevent future 'enemies' from getting to Hubbard or other top Sea
Org officers.
8. "We accomplished the creation of a new intelligence, PR and legal machine by
establishing the Office of Special Affairs (OSA). Under Hubbard's and Miscavige's close
supervision, I organized OSA to effectively continue to silence potential critics and defectors
without exposing Hubbard, Miscavige or the Scientology organizations to legal liability. For the
Page 2
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next five years, until Hubbard's death, we worked to extinguish his outstanding criminal and
civil liabilities. I was also involved in the corporate re-organization that was intended to buffer
Hubbard and Miscavige from liability.
9. "A year after Hubbard's death, Mr. Miscavige informed me that he needed a defensible
corporate position to enjoy the protections of the new corporate structure. To accomplish this
goal, Miscavige used his Sea Org rank to seize control of all Scientology corporations.
Miscavige and I accomplished this by carrying out a coup at the highest, controlling corporation
in the Scientology hierarchy, Religious Technology Center (RTC). Miscavige and I, with two
other high-ranking Sea Org members, dressed in fully decorated Sea Org naval officer uniforms,
forcibly expelled the officers and directors of RTC and coerced them to relinquish their corporate
positions to us. If asked, all the Sea Org members involved, would falsely swear that the changes
at RTC were done in the normal course of its corporate business pursuant to long-standing policy
that testifying against another Scientologist is a high crime.
10. "! became a Director and the President of RTC. For weeks Miscavige struggled with
creating a position for himself that would afford the full autocratic control befitting his Captain
rank while shielding him from corporate and legal responsibility for the consequences of his tight
control. Mr. Miscavige finally settled on the title 'Chainnan of the Board, Religious Technology
Center.' While never holding a corporate officer's position, Miscavige could legally claim he
simply passively passed upon the proposals of the corporate and ecclesiastical officers ofRTC in
the same manner as in any legitimate corporation. According to RTC's articles and bylaws, its
only authorized function is to police the 'proper use of the trademarks of Dianetics and
Scientology.'
11. "As the all-powerful head of the Sea Organization, David Miscavige operated in much
the same manner as Hubbard. Miscavige created for himself the public appearance of an arm's
length title for the outside world to see. Beneath the appearance, he exercised total control over
all Scientology organizations through his supreme rank as Captain of the Sea Org.
12. "In fact, from the day our forced corporate takeover began in March of 1987, Miscavige
ran the entire Scientology corporate network with no regard for corporate separateness or
controls. He managed with an obsessive, micro-managing style. For the next 17 years that I
worked as Miscavige's direct aide, he ran the Scientology network as tightly as a naval captain
runs a military vessel. All the while we communicated to the world at large, including through
om own false declarations, that Miscavige's role was the same as that of any corporate board
chaitman. We claimed that he operates through the RTC board of directors to oversee the
operational management of RTC's corporate and ecclesiastical officers. We also falsely denied
that Miscavige was in any way involved in the management of any Scientology corporation.
13. "Meanwhile, Miscavige set up a mechanism to control Church of Scientology
International (CS!), Scientology's primary management corporation. Miscavige created an
Authorization, Verification and C01Tection (AVC) department in RTC. Miscavige required that
no strategy, program, project, or order of any kind could leave CS! to any Scientology unit
anywhere without going through RTC's AVC department. AVC's original mandate was that
nothing could issue from CS! unless it was consistent with and designed to implement the
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policies of Commodore L. Ron Hubbard. Soon, however, Miscavige changed the rules so that
nothing could issue from CSI except orders or programs implementing Miscavige's own
commands.
14. "Over the next few years, the entire Scientology corporate and ecclesiastical (Sea Org)
organization came to equate 'COB', as Miscavige became known, with "Commodore", as L.
Ron Hubbard was known. COB's orders could not be questioned or disobeyed. Through his
AVC department's control of every communication emanating from CSI, Miscavige exercised
complete control of CSI, Scientology's main operating entity. I witnessed Miscavige's control
enforced without question from anyone in RTC, CSI, or any other Scientology corporation for
the next 17 years.
15. "By the mid-1990's, Miscavige's every utterance was ruthlessly enforced throughout all
Scientology corporations. He regularly strode through Church of Scientology International's
California headquarters while barking verbal orders to anyone and everyone, from the janitors to
managers responsible for Scientology management across the world.
16. "Miscavige was always accompanied by an entourage of personal staff. A staff member
always canied a tape recorder to memorialize every word he spoke. Just before any audio tape
would run out, another recorder would be started and held by an assistant inches from his mouth
so as not to miss a single word when the first tape was replaced. Runners were on hand to rush
every completed audio tape to COB's secretarial unit. There, several typists were employed, 24
hours per day, typing every word from Miscavige's mouth, from the moment he awoke to the
moment he laid his head to rest at night. The secretarial unit culled almost every sentence from
the transcripts that contained a direction or order Miscavige issued during his daily tours through
the offices of Scientology corporations. Those excerpts were issued as written orders to the
people Miscavige had directed his comments or orders to during his tours. The orders were so
frequent and voluminous that massive rows of high-density files were filled with binders of
Miscavige's orders to RTC, CS!, and other Scientology corporations. An elaborate 'time-
machine' system was employed to track compliance with Miscavige's orders. The orders were
tracked by computers, generating automatic nudges to the recipients to send evidence of
compliance. Escalating levels of punishment were devised and enforced for non-compliance
over time.
17. "The Office of Special Affairs (OSA) is the legal, public relations, and intelligence
network of CSL One or more network representatives are employed by every Scientology
organization across the world. Each of them is operated and managed by OSA International
(OSA INT) which is housed within CSL Although OSA is formally answerable to CSI's
management, from OSA's inception in the early l 980's until my depmture in December of2004,
the formal management structure was a sham. OSA was carefully micromanaged by David
Miscavige. He exercised his control through me, Inspector General of RTC, and Mike Rinder,
Commanding Officer of OSA International.
18. "Between 1982 and 2004, it was my job to act as a go-between for Miscavige and OSA.
The manner in which we shielded Miscavige was elaborate. Much of Miscavige's control of
OSA was done "off the record." Every evening I would receive an intelligence briefing in
Page 4
writing from OSA. The briefing was usually several pages summarizing reports from private
investigators and Scientologists serving as undercover spies watching and interacting with
Scientology critics. The written briefing, contrary to established corporate policy, had no routing
information on it. That is, the daily briefing had no indication who wrote the report or who it
was directed to. If a report ever got out of the Church, it could not, on its face, be used to
incriminate any of its authors or recipients.
19. "After I read the report each day, I was instructed by Miscavige to put it into a fresh
envelope with no routing inf01mation on it. I then personally carried the envelope into
Miscavige's office and set it on his desk. I was the only person in Scientology, aside from his
wife and secretary, ever authorized such access to his desk. When Mr. Miscavige read the
reports, he would enter my office with the report in hand. He would say 'beat it' to my secretary
or anyone else who happened to be in my office. Once any visitors had left, Mr. Miscavige
would discuss the contents of the report. Often, he would instruct me to order OSA to direct an
operative or private investigator to find out something or do something concerning the target of
infiltration or investigation. On other occasions, Mr. Miscavige would joke about what was
reported about a particular target, or rant about the target's activity. When Miscavige was done
discussing the daily OSA briefing with me, he would throw the report onto my desk. That was
my cue to pick it up and shred it after he left the office and before anyone was permitted to return
to my office.
20. "For 22 years, my schedule was to wake up at least one hour before David Miscavige's
scheduled wake up time so that I could collect all important information on any matter of
concern to him being handled by the OSA network. Every morning, I was required to brief
Miscavige verbally on any major developments on matters handled by the OSA network around
the world or matters concerning security. My briefing to him would begin with major problems
which he insisted he know about. My briefing included reports about the handling of media
stories, investigations, legal cases, security breaches, and potential security situations. That
briefing would last anywhere from a few minutes on a quiet day with no major developments, to
all day when something was afoot that riveted Miscavige's attention. Miscavige would issue
orders to OSA that I had to accurately note on paper.
21. "After the conference with Miscavige, there were a number of options available for
issuing his orders, depending on their scope and the level of security required. Most often, I
would call Mike Rinder, into my office and I would briefhim verbally on Miscavige's directives.
Mr. Rinder would then return to his own office and type up the orders as written directives to
OSA. Those directives would be worded as if the orders were originated by him, with no
reference to me or RTC, and especially not to Mr. Miscavige. On many occasions, Mr.
Miscavige would require Mr. Rinder' s presence during briefings in which he wanted more detail
than usual, or wanted to issue more detailed orders than usual. In such cases, it would be my
responsibility to follow up to verify that Mr. Rinder relayed Mr. Miscavige's orders to OSA as
Rinder' s own orders.
22. "Mr. Rinder and I were ordered by Mr. Miscavige to keep secret virtually all of our
communications, and to specifically keep them secret from any other managers or staff with CS!
and RTC. All other CS! managers had little to no knowledge of any matters affecting
Page 5
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Scientology from the world outside of the Church. Except for OSA staff, Sea Org members have
little contact with the media or the world outside of their corporate duties.
23. "The highest priority OSA matters that I had to monitor and repott on several times a day
to Mr. Miscavige were ones that involved his name. If a staff member left unannounced from
the Scientology corporate headquarters, and the person had any personal knowledge of Mr.
Miscavige by way of regular contact with him, I was required to personally direct a massive
dragnet utilizing Sea Org staff from RTC and CS!, and private investigators, to hunt down that
staff member. This occuned on average a couple of times per year. I was micromanaged on
such manhunts by Mr. Miscavige personally. I would make sure the person was contacted, and
put under control and sometimes order ongoing surveillance through OSA that could last up to
several years.
24. "If a journalist mentioned anything about interest in Mr. Miscavige, I directed and
monitored every conversation between a church representative and that journalist. I prepared the
staff member in advance and debriefed him afterward, all of which I reported directly to
Miscavige.
25. "If a lawsuit named or sought discovery that involved Miscavige, I oversaw every aspect
of that litigation until Miscavige was no longer subject to inquiry. During my tenure of more
than 20 years, Miscavige micromanaged every single action that was taken by any OSA staff
member, intelligence officer, private investigator or attorney related to that matter. No OSA
operation, whether or not it involved outside professionals, could be undertaken on any matter
potentially involving the name 'David Miscavige', without Miscavige's fully-informed and
direct authorization and direction. That rule included even the potential defection of a staff
member with only tangential information about Mr. Miscavige. OSA was founded on this
policy, and I instituted it and carried it out painstakingly for 22 years, from 1982 to 2004, when I
departed RTC.
26. "For more than 20 years, the Office of Special Affairs ("OSA") of the Church of
Scientology International answered to me. Under the close supervision of Mr. Miscavige, I
directed OSA's extensive, ongoing security, intelligence, "black ops", public relations, and
criminal and civil legal matters. Mr. Miscavige obsessively micromanaged OSA's handling of
perceived threats, including the threat of former Scientologists who complained of abuses
occuning in the Church.
27. "!have read the Declaration of David Miscavige in Suppott of Special Appearance in this
case. Mr. Miscavige's Declaration is false, for the factual reasons stated above and below:
A. Miscavige's false statement: "Prior to learning of this lawsuit, I had never heard
of nor did I have any knowledge of Defendants Mr. Sloat and Mr. Drake."
28. "Mr. Miscavige has known of the Church's employment of Monty Drake since the
1990's. Mr. Drake became Scientology's primary private investigator for Texas matters in the
early 1990's. In 1996, Miscavige asked me whether we had any private detectives in the State of
Texas. I told him that we retained Monty Drake, a private investigator in the Dallas area, who
we used to investigate a former RTC executive living in Dallas. Miscavige expressed amusement
Page 6
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at Mr. Drake's name, and questioned me whether "Monty Drake" was a real name or an
undercover name. I informed him that Monty Drake was a real name.
29. "David Miscavige ordered me on several occasions between 1996 and 2004, to have Mr.
Drake obtain both specific and general infonnation on the family of Lisa McPherson. Lisa
McPherson was a young Scientologist who died while in the care of the Church of Scientology. I
relayed Mr. Miscavige's orders to Ben Shaw of Church of Scientology Flag Service
Organization and Linda Hamel of OSA. Both Ms. Hamel and Mr. Shaw sent me several reports
of Mr. Drake's investigations. !personally handed each of Mr. Drake's rep01ts to Mr. Miscavige,
during the criminal and civil litigation concerning Ms. McPherson and her family.
30. "In the l 990's, I also personally delivered to Mr. Miscavige a number of Mr. Drake's
reports concerning the Church's multiyear investigation of Alan Walters, a former Scientologists
in Texas. Mr. Miscavige read these reports of the Texas investigation and used the inf01mation
to direct OSA's activities in Texas against Mr. Walters
B. Miscavige's false statements: "I have never availed myself of the privilege of
conducting activities within the State of Texas." & "I have not made any purposeful
contacts with the State of Texas seeking any benefit, advantage, or profit." & "I
have not othenvise availed myself of the benefits and protection of Texas law."
31. "In addition to the facts stated above, the following facts demonstrate the falsity of Mr.
Miscavige's Declaration. Mr. Miscavige was intensely involved with the handling of the fallout
from the death of Lisa McPherson in Florida. He devised a strategy to bring legal action in
Texas, rather than Florida, against the executor of Ms. McPherson's estate. Mr. Miscavige said
that he did not want to litigate in the most obvious venue, Pinellas County, Florida, because he
believed it would be hostile to Scientology. He ordered me to execute his Texas litigation plan.
32. "As I carried out Mr. Miscavige's Texas strategy, he repeatedly stressed to me that no
Texas suit could be filed unless I found Texas legal counsel so connected to the local judiciary
as to assure victory to the Church.
33. "During the several weeks that I implemented Mr. Miscavige's orders in Texas, I
repo1ted to him daily. After researching the issue of which Texas attorneys to retain, I
recommended the Dallas law film of Jenkins & Gilchrist. Mr. Miscavige ordered me to bring the
attorneys to the Church's facilities in the Tampa, Florida area for a two-day tour, briefing, and
indoctrination.
34. "Mr. Miscavige ordered me to gain the Texas attorneys' confidence so they would reveal
to me the extent of their connections in the U.S. District Court in the Tyler Division of the
Eastern District of Texas. After my discussions with them, the attorneys agreed to return to
Texas and thoroughly investigate to find the Tyler attorney with the strongest ties to the three
federal judges in U.S. District Court there.
35. "!reported to Mr. Miscavige the details of my conversations with the Jenkins & Gilchrist
attorneys. Mr. Miscavige expressed mistrust of the attorneys' representations. He ordered me to
tell them that their continued retainer was conditioned on finding local counsel with such
Page 7
connections that he could walk unannounced into the chambers of any of the three federal judges
to chat.
36. "The Jenkins and Gilchrist lawyers reported to me that they had found the most
connected lawyer in the Tyler Federal Courts and they provided me with many relevant details
about the attorney's connections. I reported these favorable details to Mr. Miscavige. He
expressed disgust, however, with my failure to find a Texas lawyer whose connections would
guarantee victory to the Church.
37. "Mr. Miscavige threw a tantrum and called me a "f---'ing loser". He lectured me that he
was the only Scientologist with the dedication to stick his neck out and guarantee victory. He
said he would have to be the one to personally handle this flap, as he had handled every other
major problem of CSI's Office of Special Affairs. After more ranting and raving at me, he
ordered me to hire the local counsel selected by Jenkins & Gilchrist, with the warning that "if
they don't win, you are dead!"
38. "In December of 1995, David Miscavige ordered me to send Scientologist, Bennetta
Slaughter, a former Texan living in Florida, to the funeral of Lisa McPherson in Dallas, Texas.
His orders were for Ms. Slaughter to "handle" Lisa McPherson's grieving mother and convince
her not to investigate the circumstances of her daughter's death. Miscavige instructed that if Ms.
Slaughter had to resort to paying the mother to forget the loss of her daughter, we were willing to
'lose a couple hundred grand for this to go away.' Ms. Slaughter carried out the mission to
Dallas, while reporting to me. Ms. Slaughter reported that, in spite of her family connections,
her efforts to cozy up to Mrs. McPherson were rebuffed and she never established enough
communication to suggest paying her. I reported all the details to Mr. Miscavige. Mr.
Miscavige cursed harshly about Ms. Slaughter and then issued a number of orders about
covering up the circumstances of Lisa McPherson's death.
39. "In early 1996, Mr. Miscavige ordered me to send an OSA staff member, Brian
Anderson, to approach Mrs. McPherson in Texas to accomplish the same purpose as the
Slaughter mission. Mr. Miscavige briefed me in detail on how Mr. Anderson was to act so that
he could gain Mrs. McPherson's trust without betraying any details of her daughter's death. I
carried out Mr. Miscavige's orders and sent Mr. Anderson to Dallas, Texas. In Dallas, Mr.
Anderson asked to meet with Mrs. McPherson, but she rebuffed him. I repo11ed all the details to
Mr. Miscavige. In response, Mr. Miscavige cursed about the incompetence of Mr. Anderson and
me.
40. "It is important to understand that Mr. Miscavige's consistent custom and practice for
more than 20 years was to closely monitor and micromanage every OSA operation dealing with
Scientologists who dared to leave the Church. His involvement intensified if the person had been
at a high level in the Church hierarchy and had personal knowledge of Mr. Miscavige's
activities. As noted above, I was the highest level officer in the Church after Mr. Miscavige, and
I worked directly with him for 27 years.
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41. "No Scientologist or groups of Scientologists, including OSA, have authority to
unde1take any intelligence operation or destructive campaign against a high-ranking defector
without specific approval from David Miscavige. Furthermore, if he orders any such activities to
proceed or to cease, his orders are carried out to the letter without question. He has total and
absolute authority in all branches and all functions of the Scientology corporations."
"Fmther affiant sayeth not."
STATE OF TEXAS

COUNTY OF COMAL
ii SUBSCRIBED AND SWORN TO BEFORE ME, by the said Mark Rathbun, on this the
._Jjh_ day of September, 2013, to certify which witness my hand and seal of office.
CHRISTINE A. THOMPSON
Notary Public, State of Texas
.=;.J My Commission Expires
April 22, 2014
Page 9

Monique Rathbun V Scientology CSI S Anti SLAPP Motion Part 3

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