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MEMORANDUM IN OPPOSITION TO THE SCIENTOLOGY DEFENDANTS MOTION TO DISQUALIFY PLAINTIFFS COUNSEL Plaintiffs, Luis A. Garcia Saz and Maria Del Rocio Burgos Garcia (the Garcias), in accordance with Rule 3.01(b) of the Local Rules for the Middle District of Florida, submit their memorandum in opposition to the motion to disqualify the Garcias counsel filed by Defendants Church of Scientology Flag Service Organization, Inc. (FSO) and Church of Scientology Flag Ship Service Organization, Inc. (FSSO) (collectively referred to herein as the Scientology Defendants). I. PRELIMINARY STATEMENT This is a fraud suit. The Garcias were fraudulently induced to give significant amounts of money to the Scientology Defendants based on statements they made that were not true. The Scientology Defendants knowingly misrepresented the amount of money that was needed to

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complete specific projects. This inducement caused the Garcias to give money that was neither needed nor used for those purposes. This action seeks to uncover that fraud and remedy the injury that directly resulted from it. In response, the Scientology Defendants sought to compel arbitration conducted before a panel of Scientology arbitrators without any established arbitration procedures or principles. That motion is pending. This motion now seeks to disqualify Robert Johnson and two separate and independent law firms chosen by the Garcias to represent them, alleging that, fifteen years ago, Mr. Johnson represented the Scientology Defendants in connection with (i) the acquisition of real property in Clearwater; (ii) unrelated claims by unrelated, unnamed parties, and (iii) prior litigation in the Williams case. The Scientology Defendants argue that these alleged prior representations create a direct conflict under Rule 4-1.9 of the Rules Regulating the Florida Bar and require Mr. Johnsons disqualification. Notwithstanding their supposition and belief, the Scientology Defendants have not presented a scintilla of evidence that (i) any issue in this case was ever discussed with Mr. Johnson, (ii) he has any confidential information about it, or (iii) he even knew the Garcias during the time period he represented the Scientology Defendants. Despite this, the Scientology Defendants allege that Mr. Johnson gained an unfair informational advantage on the confidences, strategies, litigation and settlement policies and practices of the Scientology Defendants. (Defs Mot. at p. 2.) On this precarious basis, the Scientology Defendants also seek to impute a generic informational advantage to all the Garcias counsel of record (i.e., the independent law firms of Babbitt Johnson Osborne & LeClainche, P.A. and Weil Quaranta, P.A.)

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and to disqualify them.1 Their final theory for disqualification of all plaintiffs counsel of record rests on alleged communications with two former Scientology-related officials (Marty Rathbun and Michael Rinder), who indisputably left the Church of Scientology in 2004 and 2007, respectively, and since then have openly criticized the Scientology Organization in the public media and in other, unrelated litigation. The Scientology Defendants allege for the first time in over six years of public debate that through communications in this case with Messrs. Rathbun and Rinder, plaintiffs counsel unfairly acquired knowledge of the legal strengths and weaknesses of church practices and positions, how to respond to intrusive discovery, and other matters of legal strategy and tactics. (Defs Mot. at p. 2.) The motion to disqualify is meritless, nothing more than a dilatory litigation tactic, and should be denied. First, the alleged prior representation by Mr. Johnson is not the same or substantially similar to the parties or the issues in this case. Second, there is no legitimate basis to impute any claimed conflict of Mr. Johnson to the separate law firms representing the Garcias. Rule 4-1.10 is limited to situations in which counsel associate in a firm and does not apply between separate firms. In addition, the Scientology Defendants have not demonstrated that the Garcias other counsel have actual knowledge of any

Babbit Johnson Osborne & LeClainche, P.A. will be referred to in this Memorandum as Babbitt Johnson, and Weil Quaranta, P.A., now known as Weil Quaranta McGovern, P.A., will be referred to as Weil. In response to the Scientology Defendants motion to disqualify counsel for the Garcias, Robert Johnson of Gray Robinson, Ted Babbitt of Babbitt Johnson and Ronald Weil of Weil, submit their Declarations, which are attached hereto as Exhibits A, B, and C, respectively. In addition, Michael Rinder and Marty Rathbun submit their Declarations, which are attached to this Memorandum as Exhibits D and E, respectively. The Declarations will be cited in this Memorandum as: Johnson Decl. at __; Babbitt Decl. at p. __; Weil Decl. at __; Rinder Decl. at __; and Rathbun Decl. at __. 3

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confidences. Disqualification is not imputed on a public-policy rationale i.e., potential access to confidential information held by the allegedly conflicted attorney is insufficient. Further, the unfair informational advantage standard is inapplicable where, as here, the cases are not reasonably related. See Miccosukee Tribe of Indians v. Dexter Wayne Lehtinen, No. 3D12-1950, 2013 Fla. App. LEXIS 7820 (Fla. 3d DCA May 15, 2013). Babbitt Johnsons and Weils representation of the Garcias do not create an appearance of impropriety and will not infringe upon the fairness and integrity of the judicial proceedings. Yet, as the Scientology Defendants are well aware, hobbling the Garcias ability to use their chosen counsel will do just that. Finally, Florida law rejects the argument that counsel for one party ethically cannot have ex parte contact with former employees of an adverse party. H.B.A. Management, Inc. v. Estate of Schwartz, 693 So. 2d 541, 546 (Fla. 1997). The Scientology Defendants have made no showing as it is their burden to do that former employees Rathbun and Rinder have actual (as opposed to merely presumed) confidential (as opposed to publicly available) information. For the reasons set forth in this memorandum and in the accompanying Declarations, the Scientology Defendants effort to deny the Garcias their right to freely choose counsel should not be condoned. II. ARGUMENT The Scientology Defendants fail to meet their burden of proving the grounds for disqualification of the Garcias counsel of record in this case. In re: BellSouth Corp., 334 F.3d 941, 961 (11th Cir. 2003). Florida law reserves disqualification of a partys counsel as a drastic remedy that should be resorted to sparingly. Armor Screen Corp. v. Storm Catcher, Inc., 709 F. Supp. 2d 1309, 1310 (S.D. Fla. 2010). Because a party is presumptively entitled to the counsel of his choice, that right may be overridden only if compelling reasons exist. In re BellSouth Corp.,

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334 F.3d at 961. Furthermore, "[s]uch motions are generally viewed with skepticism because . . . they are often interposed for tactical purposes." Yang Enters., Inc. v. Georgalis, 988 So. 2d 1180, 1183 (Fla. 1st DCA 2008). Each of these precepts squarely applies to the Scientology Defendants motion to disqualify.2 A. Robert Johnsons Representation of the Garcias in this Litigation Does Not Violate Rule 4-1.9.

The Scientology Defendants seek disqualification of Mr. Johnson alleging that he had previously represented the Scientology Defendants on general matters and in prior litigation, which precludes his representation of the Garcias in this litigation under Rule 4-1.9 of the Rules Regulating the Florida Bar.3 There is no dispute that Mr. Johnson represented the Scientology Defendants in connection with the acquisition of the real property in Clearwater, in the Williams litigation, and in other matters unrelated to the parties and the issues in this litigation. These matters were in no sense, however, the same or substantially related to the Garcias claim against the Scientology Defendants in this litigation. (Johnson Decl. at 56-58.)
2 This is not the first time the Scientology Organization has moved to disqualify plaintiffs

counsel without any legitimate basis for doing so. See Church of Scientology of California v. McLean, 615 F.2d 691 (5th Cir. 1980) (finding that the motion to disqualify was not only without merit
but frivolous and awarding damages caused by the appeal). 3 Rule 4-1.9 reads:

A lawyer who has formerly represented a client in a matter shall not thereafter: (a) represent another person in the same or a substantially related matter in which that person's interests are materially adverse to the interests of the former client unless the former client gives informed consent; or (b) use information relating to the representation to the disadvantage of the former client except as rule 4-1.6 would permit with respect to a client or when the information has become generally known; or (c) reveal information relating to the representation except as these rules would permit or require with respect to a client. 5

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Under the controlling standard, disqualification is not required merely because the irrefutable presumption of confidence triggered by a prior representation is in place. Instead, the party moving to disqualify opposing counsel must also show that "the matter in which the law firm subsequently represented the interest adverse to the former client is the same matter or substantially similar to the matter in which it represented the former client." Junger Util. & Paving Co. v. Myers, 578 So. 2d 1117, 1119 (Fla. 1st DCA 1989); see also State Farm Mut. Auto. Ins. Co. v. K.A.W., 575 So. 2d 630, 634 (Fla. 1991). The Florida Supreme Court has approved amendments to the comment for Rule 4-1.9 that narrowly defined the concept "substantially related." Specifically, the comment to Rule 4-1.9 indicates that the Rule should not be broadly understood to favor disqualification: a lawyer who recurrently handled a type of problem for a former client is not precluded from later representing another client in a wholly distinct problem of that type even though the subsequent representation involves a position adverse to the prior client. See also Health Care & Ret. Corp. of America, Inc. v. Bradley, 961 So. 2d 1071 (Fla. 4th DCA 2007). The central premise to the Scientology Defendants motion that this case shares a general subject matter to other matters in which Mr. Johnson was involved over 15 years ago (i.e., refund cases) is fundamentally flawed. Iliana Herrera-Shorthouse v. La Cubana Bail Bonds, Inc., No. 98-1888, 1999 U.S. Dist. LEXIS 21476, at *10-11 (S.D. Fla. April 16, 1999) (actions were not substantially related merely because the actions shared a general subject matter of trademarks and client received general legal advice concerning trademark issues). Mr. Johnsons representation of the Scientology Defendants encompassed four areas: The acquisition of real property in downtown Clearwater. The drafting of standard releases. The Williams case.

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General matters unrelated to the parties and the issues in this litigation.

(Johnson Decl. at 4-7, 16, 23 and 25.) Each topic is wholly distinct from the Garcias problems in this case. First, the Garcias claim of fraud relating to the entire Super Power project cannot be squeezed into the acquisition of the real property. The Scientology Defendants do not demonstrate a single point of similarity on these two problems, other than to allege generally that Mr. Johnson was involved in the legal work relating to the purchase of the land. Second, the drafting of standard release forms for unnamed parties on unidentified issues is not substantially related, as narrowly defined under the amendments to the Rule. The Scientology Defendants have failed to demonstrate how one standard release requires disqualification in this litigation, and they cannot simply leave it to the Court to make the necessary connection to the Garcias claims. Williams, as described in detail in Mr. Johnsons Declaration, involved a completely unrelated problem against different entities than the one presented here. Williams concerned claims against the Emery Wilson Corporation relating to monies paid to that entity for services rendered by FSO and the Church of Scientology Mission of San Francisco to rehabilitate plaintiffs personality defects, which were allegedly ruining their business and marriage. (Id. at 26-28.) Nothing in Williams substantially connects the parties and the issues to those at issue in this litigation. While the Scientology Defendants allege additional general areas falling within the prior representation, of which Mr. Johnson does not have specific recollection or knowledge, they are not reasonably related to the Garcias claims, and information relating to them is all a matter of public record. (Id. at 32.) Even assuming that Mr. Johnson did handle matters involving refund claims and donations, disqualification is improper. See Morgan Stanley & Co. v. Solomon, No.

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08-81330, 2009 U.S. Dist. LEXIS 15799 (S.D. Fla. Feb. 19, 2009). Morgan Stanley is directly on point. The court held that disqualification under Rule 4-1.9 of plaintiffs counsel was not appropriate where the lawyers had previously represented Morgan Stanley in securities litigation and arbitrations involving alleged losses in the value of investments: Mr. Solomon now represents individuals suing Morgan Stanley under the same legal theories. Instead of negligence cases, Mr. Solomon pursues suits against Morgan Stanley and its brokers arising out of failed investments in securities. But like negligence cases, each of Mr. Solomon's cases involve unique facts. Here, there is no showing that Mr. Solomon defended Morgan Stanley against claims either brought by the same individuals, involving the same securities or the same brokers. Each plaintiff in the arbitrations will need to prove his or her case using evidence and witnesses that pertain to his or her unique set of facts. Id. at *11-12. Indisputably, cases based on fraud turn on their own facts. See also Hernandez v. Royal Caribbean Cruise Ltd., No. 10-21636, 2010 U.S. Dist. LEXIS 98113 (S.D. Fla. Sept. 7, 2010) (denying disqualification of a lawyer who had previously represented a client in a slip and fall case was not prevented from subsequently representing parties adverse to that client in the same type of case). Policies and practices of an organization are not static but necessarily change over time. Even assuming it to be a valid legal basis for disqualification, which it is not, Mr. Johnsons representation 15 years ago cannot reasonably be said to have given him an unfair litigation advantage in this litigation. Morgan Stanley, 2009 U.S. Dist. LEXIS 15799, at *17 (noting that several years had passed since the attorney had worked on the former clients matters); see also Rule 4-1.9 comment.

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The Scientology Defendants Effort to Disqualify the Garcias Independent Counsel Through Imputation Fails as a Matter of Law.

The Scientology Defendants present no evidence, and the Johnson Declaration clearly refutes any reasonable basis, to establish that Mr. Johnson was involved in the facts relating to the Garcias claim or even knew them during the relevant time frame. That should end the inquiry on the Scientology Defendants efforts to disqualify the Garcias counsel. Regardless, Florida law rejects any legal basis to impute the claimed conflict of Mr. Johnson to the separate and independent law firms of Babbitt Johnson and Weil that would justify their disqualification. Rule 4-1.10 does not apply to separate law firms.4 Baybrook Homes, Inc. v. Banyan Constr. & Dev., Inc., 991 F. Supp. 1440, 1443 (M.D. Fla. 1997). Reimputation of Mr. Johnsons alleged knowledge to lead counsel at two separate firms whose members are neither partners of, nor associated with, Mr. Johnson is nothing short of a "drastic" measure that would "set a disturbing precedent" which could lead to "extreme results. Id. at 1445 (quoting American Can Co. v. Citrus Feed Co., 436 F.2d 1125, 1129 (5th Cir. 1991)).5

4 Rule 4-1.10 (a) provides:

while lawyers are associated in a firm, none of them shall knowingly represent a client when any 1 of them practicing alone would be prohibited from doing so by rule 4-1.7, 4-1.8 (c), 4-1.9, or 4-2.2. [emphasis supplied]

The Scientology Defendants mistakenly rely on cases addressing Rule 4-1.10(b), which involves imputation of one lawyers knowledge of confidential information to his or her newly associated firm. Those facts are not present here. Nor is there any allegation that the independent firms of Babbitt Johnson and Weil are, in effect, one firm. Zarco Supply Co. v. Bonnell, 658 So. 2d 151 (1st DCA 1995), is thus inapposite. Likewise, reliance on the Missouri courts decision in Polish Roman Catholic St. Stanislaus Parish v. Hettenbach, 303 S.W.3d 591 (Mo. App. 2010), is not controlling. See Baybrook Homes, 991 F. Supp. at 1443 (noting the lack of any decisional authority applying Rule 4-1.10 between two firms).

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Likewise, the unfair informational standard is inapplicable to unrelated matters. See Miccosukee Tribe of Indians, 2013 Fla. App. LEXIS 7820, at *1-2. Nor can there be any reasonable argument of an appearance of impropriety, where no shared confidences relating to the Garcias claim have been established. (Johnson Decl. at 57-58; Babbitt Decl. at p. 2; Weil Decl. at 6-7; Rinder Decl. at 12-13; Rathbun Decl. at 6-7.) C. Consultation with Former Scientology Employees Is Appropriate and Does Not Warrant Disqualification of the Garcias Chosen Counsel.

Contrary to the Scientology Defendants belief, counsel for one party is not ethically prohibited from having ex parte communications with former employees of an adverse party. H.B.A. Management, 693 So. 2d at 546. The Florida Supreme Court has made it clear that "an employee's departure terminates the agency or respondeat superior connection that had previously permitted that employee to create liability for her employer or to bind or make admissions for that employer." Id. Rule 4.4-2 was not meant to prevent the solicitation of relevant information from former employees, as opposed to the rule's obvious restrictions on contacts with current employees. The supreme court explained: [b]ecause former employees cannot possibly speak for a defendant corporation, the rule against communicating with adverse parties does not apply. The court found no reason to distinguish between former employees who witnessed an event and those whose act or omission caused the event. [T]he purpose of the communication rule is not to protect a corporate party from revelation of prejudicial facts, but rather to preclude interviewing of employees who have authority to bind the corporation. Id. at 544 (citing the opinion in Wright v. Group Health Hospital, 691 P.2d 564, 569 (Wash. 1984)). Here, Rathbun and Rinder are former employees of the Scientology organization, and they have no present authority to bind the Scientology Defendants. According to the Scientology Defendants, Rathbun and Rinder (i) were removed from any positions of responsibility, (ii) left


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the Church in 2004 and 2007, respectively, and (iii) have spread their hostility in various media forms on the Internet and in court filings. (Defs Mot. at p. 10.) Specifically, the Scientology Defendants allege that Rinders actions against the Scientology Organization have included actively organizing meetings of potential plaintiffs, locating attorneys to represent them, connecting up with lawyers and the ex-members, organizing conference calls with the lawyers, and acting as the overall coordinator of what [Culkin]6 believes to be as many as 10 different lawsuits against the defendants. (Id. at 11.) Notably, this is the first time the Scientology Defendants seek to disqualify counsel for the adverse party based on Rathbuns and Rinders communications. The Scientology Defendants do not make a single reference, as they must, to any inquiries by the Garcias counsel in this case into matters that are the subject of attorney-client privilege. Nor can they legitimately make that claim. The Declarations of Ted Babbitt and Ron Weil demonstrate that no such inquiries have been made and no confidential information has been received by them. (See Babbitt Decl. at p. 2; Weil Decl. at 4-8.) The Scientology Defendants reliance on a declaration filed by Rinder in a different case is misconceived. By their own admission, the alleged statement by William Drescher, who is now deceased, is public, not confidential, information. The mundane and legally insignificant nature of the comment is further evidenced by the fact that disqualification of plaintiffs counsel

Brian Culkin, a former Scientologist who states that he made a monetary demand on the Scientology Defendants but since has reached an agreement with them, has filed a Declaration on their behalf. Nothing in that Declaration supports disqualification of the Garcias counsel. Mr. Johnsons prior representation, which terminated 15 years ago, is not substantially related to the Garcias claims in this litigation, and Culkin does not identify much less establish any confidential or attorney client communications known to or purportedly disclosed by Mr. Johnson. As Mr. Johnsons Declaration clearly demonstrates, there simply are no such communications or confidences to share. (Johnson Decl. at 34, 52.)


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was not requested in that case based on that statement. The Scientology Defendants should not be permitted to bootstrap that claim as a basis to disqualify different counsel in an unrelated case. Nor does the claimed general knowledge by Rathbun of the administration of policies concerning the monetary funds or his alleged involvement in the formulation of the arbitration clauses, warrant disqualification of the Garcias counsel. (Defs Mot. at 12.) Even assuming these alleged communications were shared, which the Scientology Defendants do not claim they were, by their own acknowledgment, the subject matter has been presented to the public as part of an ongoing reprimand by Rathbun and Rinder of the Scientology Organization. Disqualification based on the sharing of public information is unjustified. See Whitener v. First Union Natl Bank, 901 So. 2d 366, 370 (Fla. 5th DCA 2005) (granting certiorari and quashing order disqualifying counsel as harsh and unjustified where the information in question was available for anyone, including counsel, to review in public records). Finally, disqualification based on Rathbuns and Rinders communications is not required or appropriate under any circumstances. "[A]s a general rule . . . disqualification of counsel under [Florida Bar Rule] 4-4.2 is not presumptively required, and violations thereof should ordinarily be remedied in some other way." Allstate Ins. Co. v. Bowne, 817 So. 2d 994, 999 (Fla. 4th DCA 2002) (stating that the "usual remedy" is to bar the ex parte acquisition of information during discovery or bar the use of any improper communications already had). The Scientology Defendants reliance on Rentclub, Inc. v. Transamerica Rental Finance Corp., 811 F. Supp. 651 (M.D. Fla. 1992), affirmed, 43 F.3d 1439 (11th Cir. 1995), is misplaced. First, the Florida Supreme Court has now clarified that ex parte contact with former employees is not prohibited by the Florida Rules of Professional Conduct. See H.B.A. Management, 693 So. 2d at 546; Carnival Corp. and/or Carnival Cruise Lines, Inc. v. Samantha Romero and Emilio


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Romero, III, 710 So. 2d 690 (5th DCA 1998). In addition, in Rentclub, the former employee was actually employed by the adverse party at the time the lawsuit was filed. Further, he had discussed a related suit with his former employer's counsel. In addition, the former employee was a self-proclaimed fact witness who had absconded with confidential documents, which he distributed to his ex-employer's adversaries. None of those facts is present here. In contrast, in this case, both Rathbun and Rinder had left the Scientology Organization many years before this lawsuit was filed. Neither Rathbun nor Rinder is a lawyer, and neither acquired confidential information. As the Scientology Defendants acknowledge, their policies are purposefully made available to the public, and both Rathbuns and Rinders disagreement with those policies is equally available in the public forums. (Rinder Decl. at 3, 4; Rathbun Decl. at 3.) The Scientology Defendants efforts to invade the Garcias attorney-client relationships, defeat the Garcias choice of counsel and prejudice their prospects in this litigation, are unjustified. Under the controlling case law and the factual circumstances established by the Declarations of the Garcias counsel, the Scientology Defendants should not be permitted the extreme remedy of disqualification in furtherance of their tactical goal in this litigation. III. CONCLUSION For all of the foregoing reasons, the Scientology Defendants motion to disqualify the Garcias chosen counsel should be denied.


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Dated: May 28, 2013 Respectfully submitted, s/ Ronald P. Weil_______________ Ronald P. Weil, Esq. Florida Bar No: 169966 Amanda M. McGovern Florida Bar No.: 964263 WEIL QUARANTA MCGOVERN, P.A. Southeast Financial Center, Suite 900 200 South Biscayne Boulevard Miami, FL 33131 Phone: 305.372.5352 Fax: 305.372.5355 - and Theodore Babbitt, Esq. Florida Bar No: 091146 BABBITT JOHNSON OSBORNE & LECLAINCHE, P.A. 1641 Worthington Road, Suite 100 West Palm Beach, FL 33409 Phone: 561.684.2500 Fax: 561.684.6308 Counsel for Plaintiffs Luis A. Garcia Saz and Maria Del Rocio Burgos Garcia


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We hereby certify that, on May 28, 2013, we electronically filed the foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified below in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filings. F. Wallace Pope, Jr., Esq. FBN 124449 Johnson, Pope, Bokor, Ruppel & Burns, LLP P.O. Box 1368 Clearwater, FL 33757 Phone: (727) 461-1818 Fax: (727) 462-0365 E-mail: Counsel for Defendants Nathan M. Berman, Esq. FBN 329230 E-mail: Lee Fugate, Esq. FBN 170928 E-mail: Jack E. Fernandez, Esq. FBN 843751 E-mail: Mamie V. Wise, Esq. FBN 65570 E-mail: Zuckerman Spaeder LLP 101 E. Kennedy Blvd., Suite 1200 Tampa, FL 33602 Phone: (813) 221-1010 Fax: (813) 223-7961 Counsel for Church of Scientology Religious Trust

Marie Tomassi, Esq. FBN 772062 Trenam Kember Scharf Barkin Frye, ONeill & Mullis, P.A. Bank of America Building 200 Central Avenue, Suite 1600 St. Petersburg, FL 33701 Phone: (727) 820-3952 Fax: (727) 820-3972 E-mail: Counsel for IAS Administrations, Inc. and U.S. IAS Members Trust


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