LAW OFFICES OF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 401 EAST OCEAN BOULEVARD, SUITE 800 LONG BEACH, CALIFORNIA 90802-494 eadzenlinws Yous moumies eal 10 M1 12 1B 14 15 16 7 18 19 20 2 2 23 24 25 26 27 28 ® canlMbrecnenan93 sementtem BLUMBERG LAW CORPORATION JOHN P. BLUMBERG, ESQ. (SBN 70200) SINDEE M. SMOLOWITZ, ESQ. (SBN 123237) 444 W. OCEAN BLVD., SUITE 1500 LONG BEACH, CA 90802 TELEPHONE: (562) 437-0403 FILED TELECOPIER: (562) 432-0107 LOS ANGELES SUPERIOR COURT METZGER LAW GROUP A PROFESSIONAL LAW CORPORATION OCT 09 2013 RAPHAEL METZGER, ESQ. (SBN 116020) pr Agua KATHRYN SALDANA, ESQ. (SBN 251364) be 401 E. OCEAN BLVD., SUITE 800 svnatl LONG BEACH, CA 90802-4966 uTY TELEPHONE: (562) 437-4499 TELECOPIER: (562) 436-1561 Attorneys for Plaintiff LAURA ANN DECRESCENZO SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT LAURA ANN DeCRESCENZO, aka LAURA A, DIECKMAN, CASE NO. BC411018 Assigned to the Honorable Ronald M. Sohigian, Dept. 41 Plaintiffs, DECLARATION OF LAURA ANN DIECKMAN (DECRESCENZO) __IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANTS’ JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND THAT THE STATUTES OF LIMITATIONS BAR THE ACTION vs. CHURCH OF SCIENTOLOGY INTERNATIONAL, a corporate entity, AND DOES 1 - 20, Defendants. Date: October 23, 2013 Time 8:30 a.m. Dept: 41 DECLARATION OF LAURA ANN DIECKMAN (DECRESCENZO) IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANTS’ JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND THAT ‘THE STATUTES OF LIMITATIONS BAR THE ACTION10 rt 12 1B 14 Law OFFICES OF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 15 16 38 a eo 32 17 18 19 20 21 2 23 24 25 26 nie Wd msumes eS 27 28 porguperignay @ A DECLARATION OF LAURA ANN DIECKMAN (DECRESCENZO) 1, Laura Ann Dieckman, declare as follows: 1. Myname is Laura Ann Dieckman, and I am over the age of 18. My married name was Laura Ann DeCrescenzo. 2. Lam the plaintiff in this lawsuit. 3. Thave personal knowledge of the matters set forth hereinafter and, if called as a witness, T would competently testify thereto, Purpose of Declaration 4, Inthis declaration, I set forth the things that I saw, heard, read, and observed the Church ‘of Scientology (CSI) do that made me believe I could not file a lawsuit against the Church of Scientology, and that if I did, I would be subjected to severe retribution. As detailed below, I was too afraid to sue the Church of Scientology until mid-June/July 2008 when my parents told me for the first time that they were no longer Scientologists, that they believed I had been wronged by the Church of Scientology, and that they would stand by me regardless of what the Church of Scientology did or sai. Background in Scientology 5. My parents were Scientologists when I was born and I was raised in the Church of Scientology. 6. I went to Scientology schools for most of my young childhood and at age six or seven. T began volunteering at a Church of Scientology organization in Orange County. 7. Atagenine, I started working at a Church of Scientology organization in Albuquerque, New Mexico. During this time, I worked between 2-3 hours on weekdays and 5-8 hours on Saturdays. My tasks consisted of reception work, routing mail, and standing outside with a sign offering free personality tests. My initial job title was Director of Communications, and this eventually changed to Executive Director Communicator. 1 DECLARATION OF LAURA ANN DIECKWAN (DECRESCENZO) IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANTS’ JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND THAT ‘THE STATUTES OF LIMITATIONS BAR THE ACTION boLAW OFFICES OF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 401 EAST OCEAN BOULEVARD, SUITE 800 TONG BEACH, CALIFORNIA 2% Chationt hue Tan ne ¥ 8. When I was eleven years old, I was sent Los Angeles, California, with my parents’ ol consent, to receive training from the Church of Scientology in its Technical Training Corps. The ‘Technical Training Corps trains Scientologists how to become auditors (a term used for counselor in Scientology) or to become executives in Scientology. During this time, I was still employed by Scientology's Albuquerque organization, but I was working in Los Angeles. I worked from 8 a.m. to 10 pm. each day, and worked at the Technical Training Corps for a number of months. 9. When I was twelve, I was recruited to join the Church of Scientology's Sea Organization (Sea Org). The Sea Org is an internal organization within Scientology that is responsible for overseeing the delivery of Scientology throughout the world, During the recruitment process, three important promises were made to me: (1) I would be able to have kids when I was older; (2) I would be able to go home every couple of months to see my parents; and (3) I would continue to go to school. 10, _Atage twelve, with my parents’ consent, I joined the Sea Org as a full-time employee and moved away from my family in Albuquerque, New Mexico, to Los Angeles, California. At that time, Thad a seventh grade education, and I signed a billion year contract (meaning that I agreed to work for the Sea Org for a billion years). As detailed below, I remained in the Sea Org for the next thirteen years until I was twenty-five years old. Communications with Family 11, Upon joining the Sea Org, the Church of Scientology controlled my communications with my parents and family members, This control, described below, continued for the duration of my time in the Sea Org. 12, Before any incoming and outgoing mail was provided to me or sent to my family ‘members, it was opened and approved by the Church of Scientology. I know this because all of my incoming mail would arrive to me opened and because I was told by the Hubbard Communications Office (HCO) that I was required to leave any outgoing mail opened and provide it to the HCO for review before it would be sent out. The HCO handles personnel, ethics, and communications for the Sea Org. 2 DECLARATION OF LAURA ANN DIECKMAN (DECRESCENZO) IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANTS’ JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND THAT ‘THE STATUTES OF LIMITATIONS BAR THE ACTION See eee eee eee ee ee ee ee ee ee ee ee ee enter ee ee ee ee ee ee ee eee ete eee eee