& Kelly LLP. Tet case KENDALL BRILL & KELLY LLP Bert H. Deixler (70614) ‘Nicholas F. Daum (236155) 10100 Santa Monica Blvd., Suite 1725 Los Angeles, California 90067 Telephone: 310.556.2700 Facsimile: 310.556.2705 RABINOWITZ, BOUDIN, STANDARD, KRINSKY & LIEBERMAN, LLP Eric M. Lieberman (pro hac vice) 45 Broadway, Suite 1700 New York, NY 10006 Telephone: 212.254.1111 Facsimile: 212.674.4614 Attorneys for Defendant Church of Scientology International JEFFER, MANGELS, BUTLER & MITCHELL, LLP Robert E. Mangels (48291) 1900 Avenue of the Stars, Seventh Floor Los Angeles, California 90067 Telephone: "310.203.8080 Facsimile: 310.203.0567 Attomeys for Defendant Religious Technology Center SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT LAURA ANN DeCRESCENZO, Case No. BC411018 Plaintiff, Assigned for All Purposes to the Hon. Rolf M, Treu, Dept. 58 v. DECLARATION OF JESSE CHURCH OF SCIENTOLOGY DECRESCENZO IN SUPPORT OF INTERNATIONAL, a corporate entity, DEFENDANTS’ MOTION FOR RELIGIOUS TECHNOLOGY CENTER, SUMMARY JUDGMENT AND previously sued herein as Doe No. 1, a SUMMARY ADJUDICATION California Corporation, and DOES 2-20, Filed Concurrently with Motion, Mem. of Defendants. P&A, Separate Statement and Declarations of Nicholas F. Daum, Allan Cartwright, Warren MeShane and Benjamin J. Hubbard. Date: October 22, 2015 Time: 8:30 a.m, Dept: 58 Action Filed: April 2, 2009 Trial Date: December 7. 2015 250826.1 DECLARATION OF JESSE DECRESCENZO ISO OF DEFENDANTS" MOTION FOR SUMMARY JUDGMENT AND SUMMARY ADJUDICATIONwe wan een 10 " 12 13 “4 15 16 7 18 19 20 21 22 ga 23 24 25 6 27 Kendall eritt “8 ‘& kelly LLP rat DECLARATION OF JESSE DECRESCENZO I, Jesse DeCrescenzeo, declare as follows: 1, Tam the former husband of Laura Dieckman (DeCrescenzo), the plaintiff in this action. I have personal knowledge of the facts set forth in this declaration, and if called upon as a witness, I could and would competently testify thereto. 2. [married Laura in 1995, when I was nineteen years old, and Laura was seventeen, Thad met her about a year previously. At the time we met and married, we were both strongly committed Scientologists. We were also young members of Scientology’s religious order called the Sea Organization. As members of the Sea Organization, we were called upon to perform a wide variety of religious roles, as well as education and service. Our work required total commitment to our religious work, long hours, and strict discipline. I viewed the Sea Organization as my career and my religious vocation, 3. Laura and I lived together after our marriage, in a private suite for the two of us in a building that housed other members of the Sea Organization. Asa young married couple, we often talked about our work, and our religious beliefs, Laura often told me she shared a strong commitment to both Scientology and the Sea Organization. Otherwise, we were like what I believe any other married couple to be, doing household chores, having minor disagreements, but generally happy. If anything, I believe that Laura was at this time even more dedicated to her career than I was — often volunteering to work hours that cut into our family time. 4, Before we got married, Laura and I discussed having children. Laura and I both agreed that we would wait to have children, because we were so young and because we were just beginning our careers, We knew, and discussed, that having a child right away would mean the end of our careers in the Sea Organization, Sea Organization policy required “routing out” of the organization (ie., leaving the organization, but remaining a Scientologist in good standing) if one 2 2507.1 DECLARATION OF JESSE DECRESCENZO IN SUPPORT OF DEFENDANTS” MOTION FOR SUMMARY TUDGMENT AND SUMMARY ADJUDICATIONieee or wera 10 u 12 13 14 15 16 7 18 19 20 21 2 23 24 25 ne (26 = 27 Kendall Brill “8 a kelly LLP ‘was a parent with a young child. ‘The reason for this policy, to my understanding at the time, was that the obligations of a Sea Organization member were too demanding to be appropriate for parents of very young children, While we didn’t rule out having children at some point in the future, we agreed that it wasn’t the right time to have children, and would not be until we were older and ready. Thus, we agreed that Laura would take birth control pills, and we would use contraception. 5. In February, 1996, Laura told me, in a meeting with a Scientology chaplain present, that she was pregnant. She also told me that she had stopped taking birth control pills. This news came as a total shock and surprise for me. Indeed, it remains one of the most intense emotional experiences of my life. I did not feel at all ready to be a father. I felt that I was too young and not ready to take on the responsibility of raising a child. I also did not want to leave the Sea Organization, which I was very committed to and had just begun advancing within. Finally, I was angry with Laura for making this important decision unilaterally, without consulting me. After I found out that she was pregnant, Laura and I had many, many discussions about whether or not we should have a baby together. I was in favor of terminating the pregnancy. But | knew that ultimately it would be Laura’s decision as to what she would do with her own body, and that I would support her regardless. We talked at length about whether or not we wanted to be parents, and the advantages and disadvantages of having children at that point in time, We talked about our religious beliefs about abortion, and what would be the best course of action to take, consistent with our religious principles. We talked about our careers and our future. ‘We talked constantly about what to do, given the importance of the issue. 7. Atnotime did Laura tell me that anyone connected to Scientology had pressured her to have an abortion, or had otherwise “lobbied” or encouraged her to get an abortion. Our conversations centered on what we wanted our choice about parenthood to be, as a couple. 2501714 3 DECLARATION OF JESSE DECRESCENZO IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND SUMMARY ADJUDICATIONweer aweun 10 M1 12 13 4 15 16 7 18 19 20 21 22 23 24 25 26 2 27 Kendall Britt “8 & Kelly LLP Because we were having extremely intense discussions about the issue, I strongly believe that Laura would have told me if she had felt that someone was demanding, pressuring, encouraging, or lobbying her to obtain an abortion, Laura told me that her main concern with having the abortion was religious ~ she told me that L. Ron Hubbard, the founder of the Scientology religion, had written negative things about abortion in the book Dianetics, and that she was worried about the religious and spiritual consequences of abortion, 8. Noone from the Sea Organization, or any other Scientology organization, ever asked me to tell Laura to obtain an abortion. No one told me at any time that Laura should get an abortion. I never heard anyone encourage, lobby, suggest, or encourage Laura to obtain an abortion, nor did T ever hear of anyone suggesting to her that she terminate her pregnancy, To the contrary, my then-mentor and supervisor at the Church told me that I should be respectful of Laura’s decision no matter what, and that I should try to understand the difficult time that Laura was going through. 9. also spoke with my mother about the issue. She was generally opposed to abortion, and encouraged me to be respectful of Laura's choices, 10. Laura and I also talked about what our future would look like if we had a child. At the time, | knew that we could “route out” of the Sea Organization (ice, leave while still being Scientology members in good standing), and have the child. 1 could have gone to work in my stepfather’s insurance business. Laura also discussed us returning to her home town of ‘Albuquerque. While we would have had to leave the Sea Organization, I knew that we could live our lives as parents, and as practicing Scientologists, while raising a family. However, I did not want to do this. Again, I did not feel ready to be a father. I was too young, I was just beginning my career. And 1 wanted to maintain the religious career to which I was committed. 4 2501711 DECLARATION OF JESSE DECRESCENZO IN SUPPORT OF DEFENDANTS* MOTION FOR SUMMARY JUDGMENT AND SUMMARY ADJUDICATIONSoe yaw es 1 MW 12 B 14 15 16 17 18 19 20 21 2 23 24 & 25 26 ae Kendall arilt”8 & Kelly LLP 11, Eventually, after we'd discussed the issue at length for at least a week, Laura told me that she would have an abortion. She told me that she agreed that it had not been fair of her to put me in the position of a father without us deciding in advance as a couple to have a child. She also told me that she thought the abortion would be best for our careers and for our vocation of service in the Sea Organization, and that these concems were more important, religiously and spiritually, than her religious objection to abortion. That was and is my understanding of the reasons why we decided on an abortion. In short, we decided as a couple that terminating the pregnancy was better for our future and our relationship. At all times, I understood that this was our decision (and, ultimately, Laura’s decision), not anyone else’s 12. Laura made the doctor’s appointment herself, and arranged the logistical details for the-abortion. I asked my mother to provide money for the abortion, which she agreed to do, and. she gave mea check. To my knowledge, no one from the Church or the Sea Organization played a role in arranging the abortion. On the day of the abortion, Laura and I drove together in my ‘mother’s car to the doctor’s office, No one else from the Sea Organization or the Church of Scientology came with us. To my knowledge, the doctor that we saw for the abortion was not in any way affiliated with Scientology. After the abortion, Laura had a few days off to recover, and then went back to work. While she was emotionally affected by the experience, she never at any time told me that she thought the abortion had been a mistake or the wrong thing to do, or that she felt forced into it. 13. My understanding at the time, in 1996, was that had Laura and I wished to leave the Sea Organization to have our child, we could easily have done so. To remain Scientologists in good standing, we would have had to use the process known as “routing out,” a process lasting no more than a few weeks to a month, in which we would have to participate in a “confessional” (Le, religious discussion about the reasons for leaving) and train our replacements to do our then- 5 2501711 ‘DECLARATION OF JESSE DECRESCENZO IN SUPPORT OF DEFENDANTS” MOTION FOR SUMMARY JUDGMENT AND SUMMARY ADJUDICATIONNM Kendall Britt & kelly LLP Bow aa 10 u R 13 4 15 16 7 18 19 20 2 2 23 24 25 26 27 "8 current jobs. I was and am very familiar with the process by which Sea Organization members “route out” to have families, because I had seen it happen many times by 1996, and have seen it happen many times since. Generally within a few years of Laura’s pregnancy, for example, my friends the Jensens and the Bellottis, two married couples who were also Sea Organization ‘members, routed out of the Sea Organization in order to have children. Not only did they remain Scientologists in good standing, but we remained friends. 14, Indeed, I myself later routed out of the Sea Organization in order to have children, when my current wife, another member of the Sea Organization whom I married after Laura and I divorced, became pregnant with our first son. This happened in 2010. By 2010, I was much older and did feel ready to be a father. It was not at all a burdensome process to “route out.” The routing out process took a few weeks,-in which I trained my replacement for my job, lived part- time at my Mother's house, and made plans for my new career. Sea Organization members and the Church were entirely supportive of my decision to leave the organization in order to raise a family. I have remained friends with many of my colleagues from that time. 15, In 1996, it was also my understanding that we could have left the Sea Organization without “routing out,” simply by leaving. This, however, would have violated Sea Organization policy, and would have had negative consequences for our standing in the religion. At the time in 1996, I was a highly religious person who did not want to leave the Sea Organization in that way, ‘and Laura was highly religious as well. In our conversations, we never even discussed the possibility of leaving without routing out. 16. By 2001, Laura was having increasing difficulties in the Sea Organization, which I believe she was hiding at home, Eventually she got into some trouble for, as she eventually told me, theft and lying. I was surprised to lear this, as Laura hadn’t discussed these problems with me. In 2001, she took some money which I had set aside for purchasing a motorcycle, and left the 6 2501711 DECLARATION OF JESSE DECRESCENZO IN SUPPORT OF DEFENDANTS" MOTION FOR SUMMARY JUDGMENT AND SUMMARY ADJUDICATIONcota So wm a a 1 W 12 B 14 15 16 "7 18 19 20 21 22 Bet 23 2d) 25 26 a7 eat ae Kendalt.Brill “8 & Kelly LLP ist ca place where we were staying to go stay with her Grandmother, who was not a Scientologist. I was deeply concerned for her and was worried about both her and our marriage. I called her and spoke with her and tried to encourage her to come back. Eventually she agreed to come back 17. Laura agreed, after a decision by the relevant group of clergy at the Sea Organization, to join the “RPF,” a program of religious discipline and training in which Sea Organization members live together, perform light manual labor, and work to help one another and themselves spiritually. I am and was intimately familiar with the RPF, because I had previously (before 2001) helped to supervise the program. At the time, in 2001, I was angry that Laura was joining the RPF, because it would mean that we would be separated. However, I knew that her going through this program would help her regain her standing as a Sea Organization member (which she told me was something that she wanted) and would help our relationship. 2501711 7 DECLARATION OF JESSE DECRESCENZO IN SUPPORT OF DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND SUMMARY ADJUDICATIONKendall Brill & Kelly LU 10 u 12 13 14 15 16 7 18 19 20 2 22 23 24 25 26 2 8 18. It was my understanding, both at the time and since, that Laura could have left the RPF at any time, while remaining a Scientologist in good standing, simply by routing out. Indeed, Thave known many Sea Organization members who were in the RPF who decided that they did not want to remain in the program, and left it. I have also known many people who have completed the RPF program and continued on with their careers as successful Sea Organization members. It was and is perfectly possible, to my understanding, to leave the RPF while remaining a Scientologist in good standing, although doing so will mean leaving the Sea Organization, While she was in the RPF, Laura and I saw each other many times. She never told me that she wished to route out, leave the RPF, leave the Sea Organization, or otherwise cease her progress in the RPF. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that I executed this document on a Uth 2015, at Los Angeles, California, Jeskp DeCrescenzo 8 2501714 DECLARATION OF JESSE DECRESCENZO IN SUPPORT OF DEFENDANTS” MOTION FOR SUMMARY JUDGMENTIAND SUMMARY ADJUDICATION