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1DECLARATION OF PLAINTIFF MARC HEADLEY
12345678910111213141516171819202122232425262728BARRY VAN SICKLE - BAR NO. 986451079 Sunrise AvenueSuite B-315Roseville, CA 95661Telephone: (916) 549-8784E-Mail: bvansickle@surewest.netAttorney for Plaintiff MARC HEADLEY
UNITED STATES DISTRICT COURTCENTRAL DISTRICT OF CALIFORNIAMARC HEADLEY
,Plaintiff,vs.
CHURCH OF SCIENTOLOGYINTERNATIONAL, a corporateentity, AND DOES 1 - 20
 Defendants.
CASE NO. CV 09-03986 RSWL(MANx)PLAINTIFF MARC HEADLEY’SDECLARATION IN SUPPORT OFPLAINTIFF’S MOTION FOR SUMMARY ADJUDICATION OFFACTS AND CONCLUSIONS OFLAW PURSUANT TO F.R.C.PRULE 56(d)DATE: August 11, 2009TIME: 9:00 amPLACE: Spring Street Courthouse,Courtroom 21ASSIGNED TO THE HONORABLEJUDGE RONALD S.W. LEW
1)
 
I make this declaration from personal knowledge and couldcompetently testify as set forth herein if called upon to do so.
 
 
2DECLARATION OF PLAINTIFF MARC HEADLEY
123456789101112131415161718192021222324252627282)
 
My name is Marc Headley. I was a staff member of the Church of Scientology International from 1989 until January 2005.3)
 
I first joined staff in 1989 at the Association for Better Living andEducation International, located in Hollywood, CA. I signed an employmentcontract stating that I would work as an employee of the Sea Organization for 1 billion years. I was a minor and had not finished high school.4)
 
I was informed that I would receive minimum wage as my hourly pay rate, which is what I was paid for the first six months I was a staff member of the Sea Organization.5)
 
After six months, I was promoted to Golden Era Productions, locatedin Hemet, California. This is a different arm of the Church of ScientologyInternational. I was informed the rules were different for Golden Era Productionsand that now I would be paid $35 per week, as per Scientology directivesdictating pay schedules for the organization’s employees. I was required to liveat Golden Era.6)
 
At this point in time, I now had no other place to live, no other job,no other source of income and if I left the Sea Organization I would owe moneyfor training courses I had received up until that point. In my mind, I believed thatI would essentially be deep in debt if I quit or decided to leave.7)
 
As a staff member, I was required to follow the issued schedule of the organization I worked for. This was issued to all staff members regularly andincluded mandated hours to get up in the morning, get transported in to work on buses, eat breakfast, get accounted for at roll call or muster (regular meetingsthroughout the day to ensure all staff are present), work hours throughout the day,lunch, dinner, etc. During my work hours I was first required to make an exact listof what I was going to get done that day. Failure to do so resulted in disciplinary
 
 
3DECLARATION OF PLAINTIFF MARC HEADLEY
12345678910111213141516171819202122232425262728action, as did failure to get those actions completed, follow the schedule, and dowhat was required of me.8)
 
Such disciplinary actions could and did include loss of pay, loss of meal privileges, loss of canteen privileges, and several times included loss of mylodging, and requirement that I stay on the property full time, including sleepingwherever I could find a spot near my work area or office. For several different periods, I was confined to the property for months at a time.9)
 
I was required to work in order to be paid the small amount of money I was paid. If I did not work, I would not be paid. Simple as that. Thesmall amount of money I did receive weekly was used to buy toilet paper, soap,shampoo and deodorant etc and any other personal items I could afford with whatlittle was left over, such as snacks or cigarettes.10)
 
Early in my career (1990) I discovered that if I expressed any desireto leave, I would not be allowed to leave the property and would be threatenedwith never being allowed to talk to my family again.11)
 
If I wanted time off for ANY reason – whether it was for a doctor’sappointment, a trip to see family, a day off, even time off work to make a phonecall to a relative, I was required to have written approval to do so. For any trip off  base for time off, I was required to work out and provide information of how my post functions would be covered in my absence – ie. who would perform myduties while I was gone, even if for only a few hours.12)
 
I was required to do the work required of me, in the manner it wasrequired of me, to the quality standards required, and meet the production targetsthat had been set and if I failed to do so in any way, I was punished for non performance.
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