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14 15 16 a7 19 20 22 22 23 a 4S DANIED ¥ BOCKIN (State Ba? No. 76996) STAN BLUMENFELD (State Bar No. 139239) He NEIL S. JANSS (State Bar No. 162744) {CFS a Qa for Ident. O‘MELVENY & MYERS Embarcadero Center West Witress 7 275 Battcvy Street, 26th Floor Date 1S fan Francisco, California 94111 RALPH L. CISTARO, CSR (445) 984-8700 Attorneys for Defendants Margaret Thaler Singer and Janja Lalich SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO LANDMARK EDUCATION CORPORATION, case No. 976027 a corporation, DECLARATION OF STEVEN PRESSMAN IN SUPPORT OF DEFENDANTS’ SPECIAL MOTION TO STRIKE COMPLAINT (CCP § 425.161 Plaintife, vs. MARGARET 7ALER SINGER, an indivitual, JANJA LALICH, an individual, and DozS 1 through 100, inclusive, DATE: May 1996 TIME: 9:30 a.m. PLACE: Dept. 10 Defendant! I, Steven Pressman, state and declare work as an editor £ I am an author and currentl the San Francisco Daily Journal. I have personal knowledge of matters set forth in this declaration and could competently test taereto if called as a witness. 2. In 1993, St. Martin’s Press published a book that ¢ had writvea entitled Qutraccous Secrayal: The Dark Journey o x Srnard from est to Exile ("Outrageous Retrayal"). That ie a Ss 1 | took a cx: 2 | projects he 3 3.. On numerous occasious while I was writing the book, 4 | I tried to interview employees of Landmark Education Corporation 5 | ("Landmark"), including Harry and Joan Rosenberg, whom I understoo 6 | and understand to be werner Erhard’s brother and sister. No one at 7 | Landmark would agree to an interview or otherwise to provide me 8 | with ingormation related to the book. 9 4 Long before Outrageous Betrayal was even published 20 Both a2 on 12 Esq., acting on behalf of Landmark as its attorney and 43 | corporate officer, threatened to sue us for Libel. They both saia 4 4 that Werner Erhard and Landmark would seek to hola me personally us [| accountable in any lawsuit. 16 5. At the time of the threats, the book had not yeu a7 { been published, and I had not sent a copy of the manuscript to 13 | Mr. Maksym requested me to send him a copy of the 19 ipt prior to publication for purposes of identifying what he 20 | deemed to be "objectionable." I believe Mr. Schreiber made a 22 milar request. 1 declined to comply with the request. 22 6. In Qutraseous Betrayal, I wrote that an organizat 23 | called the Global Hunger Project ("Project") was created by search, TI 24 | Erhard. I also wrote that, based on extensive 25 } that the main purpose of the Project from 1977 to 1990 was not eradicate world hunger as the Project claims, but rather to sp est's mesuuge of how to achieve personal transformation book, est omerged as The Forum in 1985, and the Project continued to cperate + game purpose and in the same fashion throughout the 1977 - 1996 period 7. On June 22, 1994, the Project Ciled suit againse me, asserting libel and other related claims. I was the only named defendant in that action; the Project did not sue the publisher St. Martin’s Press. I believed then, as I do now, that the law: was a fulfillment of the threats that I had received earlier £r- Messrs. Maksym, Mr. Erhard’s lawyer, and Mr. Schreiber, Landmark 8. On February 16, 1995, I str the complaint under Cal. Civ filing that motion, was filed in an attempt to stifle trageous Serrayal While the trial court denied my § of the California Court of Appeal ns 7 ih B * 9 = i a f 3 8 decided my appeal, the Project offered to dismiss its laws I signed the follo innocuous statement : "Chapter Thi-teen of my book ‘Outrageous Betrayal -- The Dark Journey of Werner Srhard from est To Exile" accurately describes through 1991 the Global jiunger Project as I viewed it. The book describes no fact, or opinion concerning the Global Hunger Project or its operations at any time after 1991." 12. Because I only wrote about the Project's operations and 2990, and because i firmly bo a that Cl | between bed the Project, I had no problems | Thirteen accurately des: the statement. After deing so, the Proje: