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lectonisii FILED by Suse Cou of Calton, Coury ofLos Angeles on 0929/2020 0417 PM SheMiR. Carer, Executwe Oceretkat Cour byS, Bolten, Deputy Clerk Robert W. Thompson, Esq. (SBN: 250038) Casey A. Gee, Esq. (SBN: 284830) THOMPSON LAW OFFICES, P.C. 700 Airport Blvd., Suite 160 Burlingame, CA 94010 Tel: (650) 513-6111 / Fax: (650) 513-6071 Brian D. Kent, Esq. (Admitted Pro Hac Vice) Gaetano D’ Andrea, Esq. (Admitted Pro Hac Vice) M. Stewart Ryan, Esq. (Admitted Pro Hac Vice) LAFFEY, BUCCI & KENT, LLP 1435 Walnut Street, Suite 700 Philadelphia, PA 19102 Tel: (215) 399-9255 / Fax: (215) 241-8700 Attorneys for Plaintifis SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - UNLIMITED CIVIL JURISDICTION CHRISSIE CARNELL BIXLER; CEDRIC | Case No.: 19STCV29458 BIXLER-ZAVALA; JANE DOE #1; MARIE BOBETTE RIALES; and JANE DOE #2; | Assigned to Hon. Steven J. Kleifield, Dept. 7 Plaintiffs, DECLARATION OF MICHAEL RINDER vs. Date: October 5, 2020 Time: 8:30 a.m. CHURCH OF SCIENTOLOGY Dept. 57 INTERNATIONAL; RELIGIOUS TECHNOLOGY CENTER; CHURCH OF SCIENTOLOGY CELEBRITY CENTRE INTERNATIONAL; DAVID MISCAVIGE; Reservation No, 225279322219 Action Filed: August 22, 2019 DANIEL MASTERSON; and DOES | = Defendants. Od 1 DECLARATION OF MICHAEL RINDER 1, Michael Rinder, declare: 1. Tama former member of the Church of Scientology and through my involvement with the organization, | have personal knowledge of the facts set forth in this declaration and, if called as a witness, could and would testify competently to sueh facts under oath 2. I was a Scientologist from the age of 6 until the age of $2. In April 1973, afier graduating high school, | joined the Sea Organization (“Sea Org”), the dedicated core of scientology comprised of members who signed a billion year commitment to forward the aims of Scientology and live communally with other Sea Org members, largely out of touch with the outside world, In October 1973, I met L. Ron Hubbard (“Hubbard”) for the first time aboard Hubbard's ship Apollo, 3. During my time in the Sea Org, I held numerous positions within the organization including on the Board of Directors of Chuch of Scientology International. In 1981, | began working in the Office of Special Affairs, a department which I eventually came to lead. ‘The Office of Special Affairs is devoted to dealing with external facing matters of Scientology including legal and government relations, dealing with the so-called enemies of Scientology, and media and public relations. [ oversaw a great deal of Scientology litigation and directed the destruction of those deemed “enemies” of Scientology. 4. Between 1979 until his death in 1986, Hubbard was in hiding in order to avoid service of process in civil cases. During this time, David Mis avige (“Miscavige”) headed the All Clear Project to try to get all lawsuits resolved so that Hubbard could come out of hiding. 5. In 1986, following Hubbard's death, Miscavige took over control of the Chureh of Scientology. Miscavige caarefully avoids being in public or otherwise available for service of process. He often travels in an armored vehicle, flies in a private plane, and is surrounded by security personnel 10 avoid service of process, 6. For more than a decade I maintained an office in the scientology building at 6331 Hollywood Boulevard. This is the exact same building as the address of 1710 Ivar Avenue (the bui sits on the corner of Hollywood Blvd and Ivar Ave), While both addresses go to the same building and lead to the offices of Reli us Technology Center (RTC) and official address of David Miscavige and Religious Technology Center, the Ivar Avenue address is a locked door with a mail slot. There are no personnel manning that door and there is not even a bell or intercom at the door to ring for assistance. 2 DECLARATION OF MICHAEL RINDER 1 || There is nobody stationed behind the door. This is purposely set up in this way to evade service of process. Security personnel stationed at the entrance of the 6331 Hollywood Boulevard address are told to tell process servers that Miscavige can not be found there and no agent for service of process is at that address who can accept service on his behalf. 7. There is an “attempted service of process” protocol that all personnel in Religious 3 4 5 6 || Technology Center, the Office of Special Affairs, security staff manning the front desk and ALL personnel 7 || working in that building are required to learn and follow in order to ensure David Miscavige is never 8 || served. Nobody is allowed to admit that David Miscavige is in the building, or that he is EVER in the 9 || building, or that he has been seen there at any time. All process servers or even someone asking questions 0 || are to be directed to the security guards at the 6331 Hollywood Blvd entrance. Those security guards, 11 |} though responsible for the security of the Religious Technology Center offices are deliberately not 12 |Jemployees of RTC to add a further layer of deniability concerning service of process. 13 8. Nobody, even those who work in the building but are not personal staff of David Miscavige, 14 |]is permitted to travel to the 11" floor which is where David Miscavige’s office is located. Only one of the 4 15 |] elevators in the building can even stop at the 11"* floor and that requires a special key to enter. The only 16 |] access to the 11" floor is from the elevators in the lobby at the 6331 Hollywood Blvd entrance, W 9. Miscavige is “Chairman of the Board” of RTC, But this too is a sham. To avoid being 18 || engaged in civil litigation through service of the corporation, he does not actually sit on the board of 19 || Religious Technology Center. His just uses the title. 20 1 declare under penalty of perjury under the laws of the State of California that the foregoing is true 21 || and correct. 22 Executed on September 28, 2020, at Palm H: ir, Florida, Michael Rinder 3 DECLARATION OF MICHAEL RINDER