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Court of Appeal, Second Appellate District

Daniel P. Potter
on 9/11/2020
on 9/11/2020
by Maria
at 10:57:33
Perez, Deputy
PM Clerk

Peter A. Gentala
(Motion for admission pro hac vice pending)
440 First Street NW, Washington, D.C. 20001
Email: pgentala@ncoselaw.org
Telephone: (202) 393-7245
Attorney for Amicus

September 11, 2020

Hon. Justices of the California Court of Appeal

Second Appellate District
Ronald Reagan State Building
300 S. Spring St. B-228
Los Angeles, CA 90013

Re: Valerie Haney v. Superior Court for the State of California, County of Los Angeles,
No. B307452; Amicus Curiae Letter in Support of Writ of Mandate

Dear Honorable Justices:

The National Center on Sexual Exploitation (“NCOSE”) urges this Court to grant
the Writ of Mandate to address this important issue:

Did the Trial Court err by ignoring Plaintiff’s allegations of a lifetime of

physical, psychological, and emotional abuse at the hands of the institutional
Defendants, as well as evidence of duress and coercion surrounding the
execution of the arbitration agreements?


It is hard to conceive of a more comprehensive array of coercion, duress, undue

influence, and trauma than the circumstances leading to the arbitration agreements the trial
court is enforcing against the Plaintiff, Valerie Haney. From the time she was a little girl,
the Plaintiff was subjected to an unrelenting succession of physical, psychological, and
emotional abuse. The abuse continued over the course of the first three and half decades of
her life.
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
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At the age of ten she was forced to sit in a chair while adults screamed sexual threats
at her. Just five years later, those responsible for her abusive environment became her legal
guardians. Her daily life was an exhausting routine of forced labor, confinement, and
always Defendants’ controlling influence.

When, as an adult, Plaintiff—who had known nothing but environments permeated

by Defendants’ domineering and abuse—finally resolved to leave Defendants’ control for
good, she was subjected to an additional three months of constructive confinement until
she “consented” to sign sweeping legal agreements purporting to alienate all of her legal
rights to hold the Defendants accountable for their tortious and criminal conduct.

The foundation of arbitration is consent—not coercion.1 The trial court’s order

compelling arbitration inverts this principal and closes courts of justice to the Plaintiff by
enforcing unconscionable agreements that were utterly founded on coercion, duress, and
undue influence.

Accordingly, Amicus NCOSE respectfully urges this Court to grant the Writ of


NCOSE is the leading organization exposing the links between all forms of sexual
abuse and exploitation. NCOSE focuses on a wide-ranging and interrelated array of topics
including, but not limited to, child sexual abuse, child-on-child harmful sexual behavior,
compulsive sexual behaviors, demand for sexual exploitation, illicit massage businesses,
image-based sexual abuse, institutional sexual abuse, men’s violence against women, the
neurological impacts of sexual trauma, the public health harms of pornography,
prostitution, sex trafficking, sexual harassment and assault, sexual objectification,
stripping, as well as the intersection of these issues with technology.

Plaintiff’s allegations raise significant claims of physical and psychological

coercion by the Defendants in this case—including shocking allegations of sexually-
threatening child abuse. Indeed, Plaintiff’s claims closely resemble the thought and
behavior-controlling tactics used by human traffickers. Additionally, much of the abuse in
this case occurred in an institutional setting, which makes the arbitration order by the trial
court particularly unfair and harmful to Plaintiff. NCOSE is concerned that the wholesale

Stolt-Nielsen S.A. v. Animal Feeds Int’l Corp., 559 U.S. 662, 681 (2010) (citing, Volt
Info. Sciences, Inc. v. Bd. of Trustees of Leland Stanford Junior Univ., 489 U.S. 468, 469
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
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delegation of Plaintiff’s claims to a panel of arbitrators composed exclusively of the

institutional Defendants’ agents effectively closes the courthouse doors to Plaintiff.


1. The abuse Plaintiff endured throughout her childhood, including extreme

threats of rape and sexual assault, is severely harmful and should be eligible for
redress in the courts.

As early as ten years old, Plaintiff was forced to sit in a chair while adults screamed
vulgar threats in her face. Defendants menaced Plaintiff with threats of rape as well as
threats to rape a family member. (Ptnrs. Exs. To Pet. For Peremptory Writ of Mand.
(hereinafter “EP”) 1 EP 17, ¶¶ 47-8.) Obviously, severe verbal abuse such as this can be
exceeding harmful. Even nonphysical threats of sexual abuse during childhood can cause
serious harm for survivors. For example, verbal sexual threats and bullying are linked to
increased instances of post-traumatic stress disorder2 as well as suicidal ideation and self-

The adults who screamed sexual threats in the face of Plaintiff when she was just
ten years old were part of an institutional environment that would supervise and govern her
childhood. Plaintiff was “born into Scientology.” (1 EP 16 ¶ 44; 3 EP 558, ¶ 2.) She lived
the majority of her life on two separate compounds owned, operated, and controlled by
Defendants. (1 EP 16, ¶ 44; 1 EP 17, ¶ 49.) Her education was conducted almost
exclusively under Defendants’ control on these compounds and focused on Scientology
rather than the minimum course-of-study education requirements. As a result, by the age
of eight she was two full grades behind her peers. (1 EP 16, ¶ 45.)

At the approximate age of fifteen, Plaintiff’s parents signed away their parental
rights to another member of the Sea Organization (or “Sea Org”), a sub-organization of
Scientology to which they were members. (1 EP 21, ¶ 67(a).) Around this time, Plaintiff
was pressed to enter into a “billion year” commitment to serve as a loyal member of the
Sea Org.

Jessica A. Latack, Anne Moyer, Valerie A. Simon and Joanne Davila, Attentional Bias
for Sexual Threat Among Sexual Victimization Survivors: A Meta-Analytic Review,
Trauma Violence Abuse, April 2017, at 2, available at
Svein Mossige, Lihong Huang, Malanie Straiton, and Katrina Roen, Suicidal ideation
and self-harm among youths in Norway: associations with verbal, physical and sexual
abuse, Child and 21 Family Social Work, 2016 at 166 and 171.
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
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Essentially, the only authority Plaintiff knew growing up was that of Defendants.
She was never permitted to have any understanding of the role of the government in
protecting her individual rights or freedom. Defendants also raised her to be highly
suspicious and even fearful of law enforcement and attorneys. As Plaintiff put it,
“Scientology brainwashed me so that I did not understand or appreciate that I had rights as
an individual.” (3 EP 558, ¶ 5)

In its order, the trial court notes Plaintiff signed each of the agreements waiving her
legal rights to maintain a civil action outside of religious arbitration when she was an adult.
(3 EP 680-681). This, of course, misses the overall context of coercion and ignores that
from her childhood Defendant’s constructed for Plaintiff a false understanding of her
freedoms as an individual before the law. The only authority Plaintiff was permitted to
know was that of Defendants. And that was misrepresented to be all-encompassing and

2. Survivors of trafficking are commonly subjected to coercive tactics designed to

compromise their ability to exercise free and independent judgment.

Plaintiff’s claims in this suit raise clear parallels to the nonphysical, coercive
behaviors reported by survivors of human trafficking.4 To be sure, this case is not just
about psychological coercion. Plaintiff’s causes of action include claims where actual,
physical force and restraint were used to limit her freedom. (1 EP 29-30, ¶¶ 110-18 (False
Imprisonment and Kidnapping claims).) But Plaintiff also alleges that she was harmed by
Defendants’ constant use of psychological coercion. Psychologically coercive tactics that
stop short of actual physical restraint are common in human trafficking.

One important study conducted by the Los Angeles County Department of Health
interviewed survivors of human trafficking. The study used the “Biderman Framework,”
a grouping of coercive, but not necessarily physically restrictive, tactics that matched
methods sociologists have been studying since the Korean War.5 The interviewees in the
study overwhelmingly reported being treated by their traffickers consistent with these
tactics. The chart below lists each of the elements of the Biderman Framework, along with

While Plaintiff’s human trafficking claims are beyond the scope of this amicus brief, it
is impossible to imagine that the institutional Defendants will establish a fair arbitration
proceeding to privately adjudicate them. See point 3, infra.
Susie B. Baldwin, Anne E. Fehrenbacher, and David P. Eisenman, Psychological
Coercion in Human Trafficking: An Application of Biderman's Framework, Qualitative
Health Research, 2014,
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
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a description of their tactical purpose. The third column in the chart sets forth Plaintiff’s
experience of the same type of coercive tactic.

Method of Coercion6 Purpose of Tactic7 Plaintiff’s Allegations of

The Same Coercive
Behavior Used Against
Her By Defendants
Isolation Deprives victim of all 1 EP 11, ¶ 18; 1 EP 18-19,
social support. Victim ¶¶ 52, 56; 1 EP 23, ¶ 67(h);
develops an intense 3 EP 559. ¶¶ 9-10.
concern with self. Victim
becomes dependent on
trafficker/abusive boss.
Monopolization of Fixes victim’s attention on 1 EP 13, ¶¶ 29-31.
perception immediate predicament.
Eliminates stimuli
competing with those
controlled by trafficker.
Frustrates action not
consistent with compliance.
Induced debility and Weakens mental and 1 EP 11, ¶ 18-21; 1 EP 16, ¶
exhaustion physical ability to resist. 45; 1 EP 18, ¶ 51; 1 EP 22,
¶ 67(f).
Threats Cultivates anxiety and 1 EP 17, ¶¶ 47-8; 1 EP 18, ¶
despair. 52.
Occasional Provides positive 1 EP 74, ¶¶ 23-4 (“she had a
indulgences motivation for compliance. care for much of the time, a
Hinders adjustment to phone and would at times be
deprivation. totally on her own.”; 1 EP
75, ¶¶ 27, 29 (permitted to
visit family).
Demonstrating Suggests futility of 1 EP 12-13, ¶ 28; 3 EP 558,
omnipotence resistance. ¶ 3 (“I was told that I could
never go to the police
and/or any government
agency, because they were
the enemy of
Scientology.”); 3 EP 560, ¶

Id., Table 1, at 2.
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
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12 (physically restrained
from leaving); 1 EP 11, ¶
17 (practice of separating
children from parents).
Degradation Makes cost of resistance 1 EP 18, ¶¶ 52, 54 (“forced
more damaging to self- to reveal entire sexual
esteem than capitulation. history”).
Reduces victim to ‘animal
level’ concerns.
Enforcing trivial Develops habits of 1 EP 23, ¶ 67(h).
demands compliance.

In this case, the Defendants argue that Plaintiff was not actually, physically confined
against her will.8 Even if this were true, it ignores the significance of the combined effect
of Defendants’ longstanding course of conduct toward the Plaintiff. The authors of the Los
Angeles study explain the aggregate effect of these particular coercive tactics:
Structures of coercion and fear become psychological boundaries that shape
the relationship between the trafficker and the trafficked person, keeping
victims mired in their situations even without physical restraint. It is often
difficult for health professionals, as well as the lay public, to understand
why trafficked persons do not escape [] or express a desire for assistance
when encountering law enforcement, health care providers, or other
Exploration of the tactics of psychological coercion thus allows for a more
nuanced and complex appreciation of the trauma experienced during human
trafficking, breaking down the false dichotomy between freedom and
captivity. Traffickers maintained control over their victims by creating a
psychological “captive environment” similar to that experienced by those
who are physically imprisoned against their will []. Even without locks and
chains, trafficked persons are trapped.9
Additionally, Plaintiff’s claims raise the question of the level of undue influence
Defendants have exercised over her. There is a growing understanding of the important
role that undue influence plays in human trafficking. In 2015, an FBI bulletin advised law
See, Defs. Reply in Sup. of Defs. Mtn. to Compel., Arb. 3 EP 583 (“her allegations of
‘unlawful confinement’ are impossibly vague (what does ‘psychologically restricted’
mean? [])(citation omitted); and Order Granting Mtn. to Compel Arb. at 3 EP 680 (noting
Defendants claims that Plaintiff had “growing areas of responsibility within the church.
She held various position [sic] of growing importance over many years.”).
Baldwin, et al, supra note 5, at 8 (citations omitted) (emphasis added).
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
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enforcement agencies across the country that “Undue influence—mind control, thought
reform, and psychological power—often is endured by trafficked victims.”10 The bulletin
goes on to present the well-known “Human Trafficking BITE Model” for focusing on
“traffickers’…capacity to control victims by undermining their ability to think and act

The BITE model focuses on four areas: (1) Behavior; (2) Information; (3) Thoughts;
and (4) Emotions. These four areas fit the Plaintiff’s claims in this case.

• Concerning behavior, the model examines ways that traffickers control the day-to-
day “physical reality” of trafficked persons. This includes rules controlling where
they live, their diet, sleep patterns, finances, and access to education.
• With regard to information, the model focuses on a trafficker’s efforts to discourage
independent thought through tactics like control over a trafficked person’s access to
information from outside the controlled environment, fostering suspicion of
“outsiders,” withholding information, and outright lying.
• The thoughts portion of the model identifies a trafficker’s efforts to exert control
over the trafficked person’s subjective perception of themselves. Tactics for
thought control include giving the individual a new name or identity, manipulating
memories through questioning or planting false memories, and casting other
systems of belief as “illegitimate, evil, or not useful.”
• Finally, the model examines emotions, which includes deliberate manipulation of
feelings, intentionally causing fear and insecurity, and using threats.11

The correlation between the Plaintiff’s claims and these well-known coercive tactics that
human traffickers use to gain undue influence is striking.12 Plaintiff’s long history of being

Larry Alvarez and Jocelyn Canas-Moreira, A Victim-Centered Approach to Sex
Trafficking Cases, FBI Law Enforcement Bulletin, Nov. 9, 2015,
See Kathleen M. Preble, Under their “control”: Perceptions of Traffickers’ Power and
Coercion Among International Female Trafficking Survivors During Exploitation, 14
Victims & Offenders: An International Journal of Evidence-based Research, Policy, and
Practice, 2019, issue 2, abstract available at:
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
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controlled by Defendants undermines the validity of the arbitration agreements the trial
court is enforcing. Arbitration is a matter of consent, not coercion. An agreement to
arbitrate in lieu of civil litigation is a contract. It is only binding if the underlying elements
of a contract are present and fraud, duress, or coercion are absent. Here, the vast majority
of the Plaintiff’s life—including her formative childhood years—was spent in
environments dominated by the Defendants’ control.

The Defendants make much of the fact that after Plaintiff got away from
Defendants’ compound known as “Gold Base,” she returned to go through the official
“routing out” process for a Scientologist to leave the faith. Yet, the Plaintiff’s testimony
shows how even the process of leaving was again dominated by Defendants’ coercive
The Church assured me this process [of leaving] would take no more than
three weeks. Instead I was held for three months and again Scientology
treated me like a prisoner. I was forced to do everything with a ‘handler,’
including using the bathroom, showering, and sleeping. I was made to do
videotaped interrogations in which I was forced to make false confessions
about myself and provide false positive testimonials about my experiences
with [Defendants].
During the routing out process, I was made to sign the departure documents
in a room with only Scientology's general counsel and a man armed with a
gun. I do not know the contents of any of the documents I signed. I was not

Cultural practices also actively reinforce victims’ situational

understanding and belief that there is no escaping the abuse they are
suffering [] found that, among the labor trafficking victims studied, threats
or use of violence, deprivation, intimidation and control, and threats of
law enforcement action were frequently used by traffickers used to control
their victims. Traffickers use other forms of invisible physical restraint,
such as sleep deprivation, so as to reduce the victim’s ability to rationally
contemplate their situation and plot their escape []. Similarly, [one study]
found that traffickers would humiliate and shame their victims, which
translated into perceptions that it was the victims’ fault they could not
support their families, undermining their ability to proactively seek
Id. at 3 (citations omitted).
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
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given copies of the documents. I signed any document that was given to me
because I just wanted it to be over and to get out of there.13
The coercion and undue influence in these allegations are palpable. Somehow, the Trial
Court found a way to question whether the presence of a man with a gun was materially
While Plaintiff does specifically attest that a ‘man with a gun’ observed her
sign the Departure Agreement, which, if true, may be circumstantial
evidence that the Departure Agreement was entered into due to duress or
coercion, but [sic] she does not explain what this man did to coerce her to
sign. Also, it does nothing to show that the earlier agreements were entered
into due to duress or coercion.14
This ignores the whole coercive context, including Plaintiff’s clear allegations that she was
not free to leave until she signed the agreements and made the statements against her own
interest to Defendants’ satisfaction. (3 EP 560-61, ¶¶ 13-15.)

3. The arbitration agreement is manifestly unfair because it delegates all of

Plaintiff’s ability to seek justice for the abuse she endured to a panel of individuals
committed to the very institution that perpetuated her abuse and allowed it to occur.

Defendants abused Plaintiff as a child. Adults threatened to rape her and then her
mother. At just ten years old she was told, “You are going to suck my dick.” These are
just examples of the abusive threats that Plaintiff endured at the hands of Defendants.
“[T]here were many others.” (1 EP 17, ¶ 48.) These shocking allegations highlight an
important distinction between the parties. They are not arms-length parties to a business
transaction—nor are they simply employer and employee (though for quite some time there
was an employment relationship and Plaintiff’s rights as an employee before the law are a
portion of this case). The relationship between Plaintiff and Defendants spans over 30 years
and includes significant periods of time in which Plaintiff was in Defendants’ care as a
minor. Plaintiff is seeking justice, in part, for harms she suffered while in the care and
control of an institution. Survivors of abuse in institutional settings experience trauma, that
is uniquely harmful and poses distinct challenges for recovery.15 These challenges are both

Decl. of V. Haney in Support of Pls. Opp. To Defs. Mtn. to Compl. Arb. 3 EP 560,
Order granting Pls. Motion Compelling Arb. at 3 EP 681.
See generally, Carly Parnitzke Smith and Jennifer J. Freyd, Institutional Betrayal,
American Psychologist, Sept. 2014,
https://doi.apa.org/doiLanding?doi=10.1037%2Fa0037564; Brigitte Lueger-Schuster B,
Dina Weindl, Viktoria Kantor, et al. Resilience and mental health in adult survivors of
child abuse associated with the institution of the Austrian Catholic Church. Journal of
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
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physical and psychological. For example, one study found that women whose abuse was
the result of “institutional betrayal” reported more severe post-traumatic symptoms such
as anxiety, sexual dysfunction, disassociation, depression, and sleep problems than
survivors of abuse in other settings.16

The institutional backdrop of this case is crucial to the validity of the agreements to
arbitrate Plaintiff’s claims. Ultimately, this appeal will determine whether the very
institution that abused the Plaintiff will sit in judgment of her claims. “The ultimate issue
in every [arbitration] case [where unconscionability is contested] is whether the terms of
the contract are sufficiently unfair, in view of all relevant circumstances, that a court should
withhold enforcement.” Davis v. Kozak, No. A156234, 2020 WL 5000760, at *3 (Cal. Ct.
App. Aug. 19, 2020) (citing Sanchez v. Valencia Holding Co., LLC (2015) 61 Cal.4th 899,
912, 190 Cal.Rptr.3d 812, 353 P.3d 741 (Sanchez).). As the California Supreme Court has
the core concern of the unconscionability doctrine is the absence of
meaningful choice on the part of one of the parties together with contract
terms which are unreasonably favorable to the other party. The
unconscionability doctrine ensures that contracts, particularly contracts of
adhesion, do not impose terms that have been variously described as overly
harsh [] unduly oppressive [] so one-sided as to shock the conscience [] or
unfairly one-sided[]. All of these formulations point to the central idea that
the unconscionability doctrine is concerned not with a simple old-fashioned
bad bargain [], but with terms that are unreasonably favorable to the more
powerful party[]. These include terms that impair the integrity of the
bargaining process or otherwise contravene the public interest or public
policy; terms (usually of an adhesion or boilerplate nature) that attempt to
alter in an impermissible manner fundamental duties otherwise imposed by
the law, fine-print terms, or provisions that seek to negate the reasonable
expectations of the nondrafting party, or unreasonably and unexpectedly
harsh terms having to do with price or other central aspects of the
Sonic-Calabasas A, Inc. v. Moreno, 57 Cal. 4th 1109, 1145, 311 P.3d 184, 202–03 (2013)
(citations and quotations omitted) (emphasis added); see, e.g., Lange v. Monster Energy
Co., 46 Cal. App. 5th 436, 449, 260 Cal. Rptr. 3d 35, 45 (2020) (holding that waiver of

Traumatic Stress, 2014, https://onlinelibrary.wiley.com/doi/abs/10.1002/jts.21958; and

Carly Parnitzke Smith and Jennifer J. Freyd, Dangerous Safe Havens: Institutional
Betrayal Exacerbates Sexual Trauma, Journal of Traumatic Stress, Feb. 26 2013,
Smith and Freyd, Dangerous Safe Havens, supra note 15 at 122.
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
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“punitive damages as a remedy for all nonstatutory claims” is “substantively

unconscionable regardless of its mutuality.”).

Moreover, there is nothing in the record that can possibly provide any confidence
that Defendants are willing to provide a fair venue for arbitration of Plaintiff’s claims. On
the contrary, far from showing any concern for the abuse Plaintiff experienced in their care,
Defendants have publicly attacked her character, including offensive claims that she was
“involved in rampant sexual promiscuity” (1 EP 24, at ¶ 73), and bizarre remarks such as
the claim that she was a “fail[ed] condom saleswoman.” Indeed, these attacks on Plaintiff’s
character remain on Defendants’ website.17 These offensive and malignant statements are
clear evidence that Defendants’ are completely unwilling and incapable of providing a
neutral and fair arbitration.

The trial court ignored the backdrop of institutional betrayal that is the foundation
of all of Plaintiff’s claims. It is tragically common that institutions that have allowed abuse
to occur within their control often prioritize their own reputations over the wellbeing of
survivors.18 Defendants’ conduct to date, however, is an extreme example of attacking the
victim. Without this Court’s intervention, the arbitration will be nothing more than a cruel
forum for re-traumatization.


Accordingly, for the reasons listed above, NCOSE respectfully requests that the
Writ of Mandate be granted.

Respectfully submitted,


Peter A. Gentala
(Motion for admission pro hac vice pending)
Attorney for Amicus
Church of Scientology International, Leah Remini’s Paid Liar: Valerie Haney Sells
Her Soul to the Devil and Destroys Her Family,
https://www.leahreminiaftermath.com/articles/leah-reminis-paid-liar.html (last visited
Sept. 11, 2020).
See, e.g., Smith and Freyd, Institutional Betrayal, supra note 14, at 580 (“Institutional
betrayal may remain unchecked when performance or reputation is valued over, or
divorced from, the well-being of members.”).
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
Page 12 of 14

Proof of Service

(C.C.P. §1013(a), 2015.5)

I, the undersigned, hereby declare under penalty of perjury as follows: I am a citizen

of the United States, over the age of eighteen years, and not a party to the within action;

my business address is 440 First Street NW, Suite 840, Washington DC 20001 and worked

I on this filing remotely from Gilbert, Arizona. On this date, I served the interest parties in

this action the within documents: Amicus Letter in Support of Writ and Application to

File Amicus Brief; via the court’s online True Filing system as follows:


Executed at Gilbert, Arizona on September 11, 2020

Peter A. Gentala
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
Page 13 of 14

Haney v. Superior Court and Church of Scientology Intl. et al.
(B307452 | Trial Ct. No. 19STCV21210)

Valerie T. McGinty, Esq. Attorneys for Plaintiff/Petitioner

Law Office of Valerie T. McGinty Valerie Haney
524 Fordham Road
San Mateo, CA 94402
Telephone: (415) 305-8253
Facsimile: (415) 373-3703
Email: valerie@plaintiffsappeals.com

Marci Hamilton, Esq.

University of Pennsylvania
Fox-Fels Building
3814 Walnut Street
Philadelphia, PA 19104
Telephone: (215) 353-8984
Facsimile: (215) 493-1094
Email: hamilton.marci@gmail.com

William H. Forman Attorneys for Respondents

(wforman@scheperkim.com) Scientology Inc.
David Scheper
Scheper Kim & Harris LLP
800 West Sixth Street, 18th Floor
Los Angeles, CA 90017-2701

Robert E. Mangels
Matthew D. Hinks (mhinks@jmbm.com)
Jeffer Mangels Butler & Mitchell LLP
1900 Avenue of the Stars, 7th Floor
Los Angeles, CA 90067-4308

Jeffrey K. Riffer (jriffer@elkinskalt.com)

Elkins Kalt Weintraub Reuben Gartside
10345 West Olympic Boulevard
Hon. Justices of the Court of Appeals, Second Appellate District
September 11, 2020
Page 14 of 14

Los Angeles, CA 90064