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Robert W. Thompson, Esq. Kristen A. Vierhaus, Esq. THOMPSON LAW OF 700 Airport Boulevard, Suite 160 Burlingame, CA 94010 Brian D. Kent, Esq. Guy D’ Andrea, Esq, M. Stewart Ryan, Esq, Lauren E, Stram, Esq LARFEY, BUCCI & KENT, LLP SCHEPER KIM & Harris LLP Dawid C. Scheper (213) 613-4670, dscheperscheperkim.com August 1.2019 Jeffrey P. Fritz, Esq. SOLOFF & ZERVANOS, P.C. 1525 Locust Street, 8th Floor Philadelphia, PA 19102 Marei Hamilton, Esq, University of Pennsylvania Fox-Fels Building 3814 Walnut Street Philadelphia, PA 19104 1435 Walnut Street, Suite 700 Philadelphia, PA 19102 Re: DOE [Vaterte Haney] v. Church of Sctentology International et at Dear Counsel: We write on behalf of our client, the Church of Scientology International. You have filed a complaint on behalf of “Jane Doe” ~ Valerie Haney — in Los Angeles Superior Court Complaint”). The Complaint is nothing but a vehicle for Ms. Haney’s false and deranged statements against the Church. Your prosecution of the Complaint will lead to awards and sanctions against Ms. Haney and you personally. We write to give you fair notice of these false statements, in case Ms, Haney was less than honest with you in recounting her experiences with the Church Six of you are not California lawyers, so you might not know about California Code of Civil Procedure §128.7(b) [the equivalent of FRCP, Rule 11]. It states in part: (b) By presenting to the court, whether by signing, filing, submitting, or later advocating, a pleading, petition, written notice of motion, or other similar paper, an attorney or unrepresented party is certifying that to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, all of the following conditions are met 601 West Fifth Street + 12th Floor * Los Angeles, CA 90071-2025 ‘Telephone (213) 613-4655 * Facsimile (213) 613-4656 ‘Screper Kim & Harris LLP Counsel August 1, 2019 Page 2 (1) Itis not being presented primarily for an improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation, (2) The claims, defenses, and other legal contentions therein are warranted by existing Inw or by a non-ftivolous argument for the extension, modification, or reversal of existing law or the establishment of new law. (3) The allegations and other factual contentions have evidentiary support or, if specifically so identified, are likely to have evidentiary support after a reasonable opportunity for further investigation or discovery. ‘Your Complaint presents a real problem for you and your client under §128.7(b). There is, overwhelming evidence that the Complaint is frivolous and malicious, prosecuted without probable cause, and presented to the court for the improper purpose of harassing the Church and its ecclesinctical leader, Mr Miscavige. And just ahout all of that evidence consists of statements, made by your a. Before turning to the demonstrably false assertions in the Complaint, we inform you that the Ninth Circuit has ruled that virtually identical allegations brought by former members of the ‘Sea Org were subject to summary judgment. In Headley v. Church of Scientology Int., 687 F. 3d 1173 (Sth Cir. 2012), wwo former Sea Org members, Mare and Claire Headley, cohorts of your client and of Leah Remini, brought claims for human trafficking and violations of California ‘wage and hour laws based on their service in the Sea Org. Both of the Headleys worked at the same location as your client (Gold Base). and one in the same department (film production). The Ninth Circuit threw out the claims of trafficking because there is no forced labor in the Sea Org and the Headleys had “innumerable opportunities to leave” the Sea Org, just as your elient did. ‘The court also found that the policy of disconnection was not an impermissible threat but a “legitimate consequence” under “church doctrine.” Jd, at 1180. Before the Ninth Cireuit’s ruling, the district court had granted summary judgment against the Headleys" claims alleging that the conditions of Sea Org work violated California wage and hour laws, by expressly finding that Sea Org members were religious workers and thus subject to the “ministerial exception” to wage and hour laws. Headley v. Church of Scientology, et a., CV 09-3987 DSF (C.D. Cal, Apr, 2, 2010). Scherer Kim & Harris LLP Counsel August 1, 2019 Page 3 Putting aside that there is no legal basis for the Complaint, the factual allegations are a fantasy. ‘The Complaint’s scurrilous allegations of “kidnapping” are belied by the literally hundreds of days Ms, Haney spent away from Golden Era Productions ~ including out-of-state visits to her family — before she elected each time to return to Gold to continue her religious mission. While we expect Ms. Haney to lie, we are shocked that attorneys would sign on to such an inflammatory accusation when itis so patently false. ‘The Complaint’s conclusory allegations of abuse and emotional distress are contradicted by « mountain of contemporaneous testimonials from Ms. Haney about how meaningful her experience in the Sea Org was, and how well she was treated by everyone, especially the ecclesiastical leader of the Scientology religion. But you prefer to go instead with a story which Ms, Haney was paid to partot by Hollywood reality TV producers. In short, the Complaint is full of falsehoods, and nothing shows that better than the interview your client gave when she departed the Sea Org. In that interview, she signed a Staff Departure Release Agreement. In that agreement, Ms. Haney acknowledged that she had “no claim of any kind against the Church or any Scientology Entity.” and that. if she did have any claim, she released all such claims. Ms. Haney also agreed that “religious arbitration pursuant to the Scientology system of Ethics and Justice shall be my sole and exclusive remedly for resolving any problem or dispute I may have conceming my experiences as a member of the Sea Org or as a voluntary religious worker for the Church or any Scientology Entity.” She will no doubt tell ‘you this agreement was “coerced” another lie. There is a videotape — ask your client about that = of her reviewing and signing the agreement, In that video interview, your client categorically refutes the substantive allegations in the fraudulent Complaint. The videotape of that exit interview shows that your client acted voluntarily, without undue influence or coercion. She said laudatory things about her Sea Org experiences, She said on multiple occasions that her decision to sign her Staff Departure Release Agreement was completely voluntary and that all of her statements were entirely her own. The video shows that your elient was comfortable, inquisitive, smiling, and not coerced. She asked for and received changes to the agreement which Mr. Soter, General Counsel forthe, Church, signed on behalf of the Church. Mr. Soter handed your client a staff departure transitional support allowance check on behalf of the Church, She signed a valid and enforceable release agreement. She cashed the staff departure transitional support allowance check days later, in Oregon, hundreds of miles away from any potential for undue influence. Months later, she invented excuses for violating the express terms of her agreement ~ scripted excuses which are provably false. Scuerer Kim & Harris LLP Counsel August 1, 2019 Page 4 It was only afier she became the paid assistant of Leah Remini that your elient changed her story. In order to ereate fodder for the Leah Remini television series, your client filed a Complaint with the California State Bar against Mr. Soter in an effort to distance herself from the legally binding contract she signed. Your client told the State Bar investigator that Mr, Soter represented to het at the time of her exit interview that he “would be her attorney.” ‘The claim \was preposterous. The videotape unequivocally reveals that your client told a malicious lie to the Slate Bar ~a misdemeanor in violation of Business and Professions Code §6043.5. The videotape makes it obvious that your client knew that Mr, Soter was representing the interests of the Church and that Mr. Soler never made any misrepresentations to her ‘The State Bar of California took Ms, Haney’s allegations for what they are — pure fabrication, The State Bar summarily dismissed her complaint. Maybe you should cheek in with the State Bar of California before you so eredulously swallow your client's fantasies, Your client's pathetic efforts to obtain the video of her exit interview, and the criminal lies she told as part of that, should tip you off that this ease isn’t about her at all. She is merely doing Leah Remini’s bidding — Remini is the rea Jane Doe ~ who is still smarting after her staged departure from the Church, Remini is in collusion with Mike Rinder and The Aftermath Foundation, a so-called non-profit, used to pay disgraced ex-Scientologists for material for Remini’s false TV show. The modus o sf Remini and Rinder goes back years and is likely unknown to you. Now thal their show apparently has been canceled, they are clearly desperate to devise other way’ to spread religious hate and to harm the Church and its leadership. Valerie Haney is just the latest stage-managed departure and “victim.” Remini staged her own departure from the Church to position herself as a “victim.” Did Remini and Rinder relate that history? Are you aware that their guru is Marty Rathbun who has exposed this seam publicly? Sec htips://www,voutube.com/watch?v=SasloOKUw_k ‘One thing you can’t deny knowledge of is your abuse of the “Doe” pleading allegation. California Code of Civil Procedure §367 which states: “Every action must be prosecuted in the ‘ame of the real party in interest, except as otherwise provided by statute.” Clearly, your offices did not have good cause to depart from the rule, “Jane Doe” is not the real party in interest Valerie Haney is your client, Ms. Haney appeared on national television to tell her stories, she is credited on the series, she is the paid assistant of Leah Remini, and her name appears at page fn 22 of the Complaint that you filed with the Court. You confirmed with a reporter from Law.com that “Jane Doe” is Valerie Haney. And while the Complaint asserts that the use of the “Jane Doe” pseudonym is necessary because of “the harm inflicted by Defendants.” your client's ScHpper Kim & Harris LLP Counsel August 1, 2019 Page 5 public Instagram account shows her childish attempts to draw attention to her conflict with the Church. Look at @veryfunlove to see video of Ms. Haney parading around Hollywood and dramatically posing in front of Scientology facilities while holding a bobblehead doll of Mike Rinder. Her boss, Leah Remini, is doing the filming and narration. The decision by you to use the “Jane Doe” moniker is a cynical and transparent attempt to cast your client into the role of a vietim of abuse. You can try to explain to the judge why you think someone who makes a spectacle of herself in front of Scientology facilities, while being filmed by a former TV star, is entitled to anonymity. It is a fraud, intended to cause harm to my client, which it indeed has accomplished. The Jane Doe moniker was used to generate anti-Scientology publicity, inchuing two front-page stories in US Magazine, Those stories contained charges that on their face would be viewed as falsc had the identity of your client been disclosed ~ the same woman who publicly taunted the Church and its leadership in a video directed by Remini, whose voice is clearly heard. Haney may believe she is financially immune to paying damages for this fraud but Remini, the real Jane Doe, certainly is not. Finally, from 2001 to the day she left the Sea Org, your client voluntarily signed multiple agreements, each of which released the Chureh from civil liabilities. affirmed her status as « religious volunteer, promised to resolve all disputes according to the Scripture of the Scientology on, and agreed to resolve all past, present, and future disputes strictly according to the ecclesiastical justice procedures of the Church. We assume you did not know about these. agreements, We also assume your client may not have been forthright in her disclosure to you of all that she agreed to. But you know now. Your Complaint on her behalf bypasses all of the procedures that she agreed to abide by. We expect you, as Ms. Haney’s lawyers, to counsel her to comply with the many agreements she fieely entered into. Accordingly, the Complaint never should have been filed Ifyou persist with the Complaint, we are authorized by the Church to seek all appropriate relief, against all responsible parties, as allowed by law. Given the obvious falsity of the assertions in the Complaint, we demand that you and your client dismiss the Complaint immediately. Very truly yours, el MMe 4-—2-— é David C. Schepef/and William H. Forman ScHEPER Kim & HARRIS LLP EXHIBIT B Robert E. Mangels 41900 Avenue of the Stars, th Floor rmangels@jmbm.com Los Angeles, California 90087-4308 (10) 263.8080 (310) 203-0867 Fax won mim.com Ref: 70213-0039 August 2, 2019 BY OVERNIGHT DELIVERY & ELECTRONIC MAIL, Robert W. Thompson, Esq. Jefirey P. Fritz, Esq. Kristen A. Vierhaus, Esq. SOLOFF & ZERVANOS, P.C. ‘THOMPSON LAW OFFICES, P.C. 1525 Locust Street, 8th Floor 700 Airport Boulevard, Suite 160 Philadelphia, PA 19102 Burlingame, CA 94010 Brian D. Kent, Esq. Marci Hamilton, Esq. Guy D'Andrea, Esq. University of Pennsylvania M. Stewart Ryan. Esq. Fox-Fels Building Lauren E. Stram, Esq, 3814 Walnut Street LAFFEY, BUCCI & KENT, LLP Philadelphia, PA 19104 1435 Walnut Street, Suite 700 Philadelphia, PA 19102 Re: DOK [Valerie Haney] v. Church of Scientology International et al. Angeles Superior Court Case No. 19STCV21210 Dear Counsel: ‘This firm is counsel to Religious Technology Center (“RTC”), which you have named as a defendant in the matter entitled, DOE v. Church of Scientology International et al., Los Angeles Superior Court Case No, 19STCV21210 (the “Lawsuit”). This letter shall serve as a demand that plaintiff Jane Doe (.e., Valerie Haney) immediately dismiss RTC from the Lawsuit with prejudice because there is no legal or factual basis to maintain the claims alleged against RTC in plaintif?’s complaint, Indeed, given the number of false factual allegations in the complaint, itis obvious from the face of it that you did not conduct a reasonable inquiry into plaintif?’s allegations before filing the Lawsuit, The complaint fails to state a cause of action against RTC, and the allegations disclose that the complaint is barred as a matter of law. The fact that you would file this lawsuit under a pseudonym (“Jane Doe”) when Valerie Haney has herself publicized her false allegations to the world is clear indication that the complaint was filed for an improper purpose. Should your client fail to immediately dismiss this action, she and you are subject to sanctions under California A Limited Liability Law Partnership Including Corporations / Ls Angeles» San Francisco + Orange County Robert W. Thompson Jeffrey P Fritz Brian D. Kent ‘Marci Hamilton August 2, 2019 Page 2 Code of Civil Procedure (“CCP”) § 128.7, given the many false and frivolous allegations, and based upon the legal and factual deficiencies discussed in further detail below. CCP § 128.7 provides that an attorney who presents a pleading to the court certifies that the pleading “is not being presented primarily for an improper purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of litigation{,)” and that the “the allegations and other factual contentions have evidentiary support or, if specifically so identified, are likely to have evidentiary support after a reasonable opportunity for further investigation or discovery.” CCP §§ 128.7(b)(1), (b)(). Ifa claim lacks proper evidentiary support, a pariy may move for sanctions against the party or ils allomey. Zc. al § 128.7(¢). Sanctions are appropriate where a party's conduct in asserting the claim is objectively unreasonable such that any reasonable attorney would agree that itis totally and completely without merit, Peake v. Underwood, 227 Cal. App. 4th 428, 440 (2014). ‘You are and your client are at obvious risk of a significant sanction award under these standards and an action for malicious prosecution. Most egregiously, the causes of action alleged against RTC in the complaint are clearly barred by the applicable statutes of limitations. Planttt worked for KIC tora time many years ago. None of the himitations periods tor the alleged causes of action alleged in the complaint exceed more than a few years. Yet the Lawsuit was filed well over a decade after she left RTC, many years after any applicable statute of limitation had run. The complaint offers absolutely no justification for plaintif?’s failure to bring her complaint ‘within the limitations periods. Moreover, the complaint is riddled with factual inaccuracies that are contradicted by plaintiff's own words and conduct. In particular, and as it relates to RTC, there is overwhelming evidence in plaintifP's own writings and oral statements demonstrating her happiness with and commitment to working for RTC and traveling the world. And more to the point, there is a mountain of evidence of which your client is well aware that shows that she was not someone who ‘was held against her will or was a vietim of “kidnapping” or “human trafficking” as the complaint implausibly and scurrilously alleges. Further, the complaint fails to even state a cause of action against RTC, There are no allegations of misconduct on the part of RTC whatsoever. Plaintif's practice of combining multiple parties into the single term, “defendants,” and failing to identify the party against whom the allegations are made, is improper and intended only to allow plaintiff to name multiple parties even though she knows she has no viable claim against RTC. As you know, plaintiff was a member of Scientology's religious order (Sea Organization). Upon joining RTC, plaintiff signed an RTC staff covenant in which she acknowledged that RTC staff members serve pursuant to religious commitment and conviction Robert W. Thompson Jeffrey P Fritz Brian D. Kent Marei Hamilton August 2, 2019 Page 3 rather than for monetary gain, In that regard, the allegations are substantively identical to those alleged in the Headley v. Church of Scientology Int., 687 F. 34 1173 (9th Cir. 2012) lavrouit. In fact, Claire Headley worked at RTC at the same time as plaintiff. Headley’s lawsuit alleged the same causes of action based upon the same essential set of false factual allegations. The District Court summarily adjudicated the Headleys’ claims in a decision that was unanimously affirmed by the Ninth Circuit because the record showed that the Headleys “joined and voluntarily worked for the Sea Org because they believed that it was the right thing to do, because they enjoyed it, and because they thought that by working they were honoring the commitment that they each made and to which they adhered.” Id. at 1179-80. ‘You should note that the undersigned were counsel for RTC in the Headley lawsuit, both in the District Court and the Ninth Cireuit. Here, the evidence is overwhelming, including a multitude of similar statements in writing and on video from Ms. Haney expressing how happy she was working for RTC, Over a decade hence, a court will not permit Ms. Haney to change her mind and recharacterize her experiences in hindsight simply because she began working for Leah Remini’s television show. Any reasonable attomey would have conducted basic research into the viabality of the claims alleged in the complaint and concluded they failed as a matter of law under Headey. Accordingly, should plaintiff fail to dismiss the entirety of her complaint against RTC for the reasons set forth above, RTC will seek all appropriate relief against all responsible parties. Sincerely, ROBERT F. MANGELS & MATTHEW D. HINKS of Jefffer Mangels Butler & Mitchell LLP REM:mdh