EXHIBIT
JEF'FREY MITCHELL,
P.C.
ATI'ORNEYS
AT LAW
Via Email:
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Ronald
P
Weil, Esq. Weil, Quaranta, McGovern P.A. 200
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Biscayne Blvd., Suite 900 Miami, FL 33131
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ia
Email:
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Theodore Babbitt, Esq. July 12, 2013 Babbitt, Johnson, Osborne& Le Clainche, P.A.
1641
Worthington Rd., Suite 100 West Palm Beach, FL 33409
V
ia
Email: wallvp
(ii;jp
Orm.com
F. Wallace Pope, Jr., Esq. Johnson, Pope, Bokor, Ruppel Burns, LLP
911
Chestnut Street Clearwater, FL 33756
RAY
B.
JEFFREY
BOARD
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BY
TEXAS BOARD
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Re:
Case No. 8:13-CV-220-T27 TBM; Luis
A
Garcia Saz and wife, Maria Del Rocio Burgos Garcia
v
Church
of
Scientology Religious Trust; et al, in the United States District Court, Middle District
of
Florida, Tampa Division. Dear Counsel, Please be advised that I represent Brian Culkin. The Scientology defendants have dragged him against his will into the above-referenced litigation. They have misused a declaration he signed as part
of
a confidential exit interview. Exit interviews and privileged documentation are routine in Scientology. Before he signed the declaration, Mr. Culkin was assured
by
Sarah Heller that it was for the Church's internal use only . Mr. Culkin was not represented by counsel in his confidential exit interview. He has no legal training or expertise.
f
he had been informed that his declaration might
be
used against the plaintiffs in this case, or in some other adversarial way, he would have refused to sign it. The. Scientology defendants ·violated his rights
of
confidentiality by
Ronald
L
Weil, Esq. Theodore Babbitt, Esq.
F
Wallace Pope, Jr., Esq. July 12,2013 Page 2 filing the declaration in this suit without his informed consent. As the Scientology defendants know all too well, Mr. Culkin wants
no
part in controversies, disputes, or proceedings with the Church. By their deceptive actions in connection with this suit, the Scientology defendants have caused Mr. Culkin considerable mental anguish. He feels betrayed by their public violation
o
trust and by their use
o
factual distortions
in
their pleadings. They have publicly given the appearance that
Mr
Culkin supports them in their attack on the plaintiffs legal team in this case. Nothing could
be
further from the truth.
Mr
Culkin respects those individuals and is unaware
o
any wrongdoing on their part. The Scientology defendants motion to take Mr. Culkin s deposition
is
designed
to
give the impression that he
is
unwilling
to
testify because
o
intimidation
by
the plaintiffs, their legal team, and their sympathizers. This
is
false. As the Scientology defendants. know,
Mr
Culkin s distress and anger was with the Scientology defendants. He complained to them in the strongest possible terms about their outrageous, inexcusable behavior. The public outcry against
Mr.
Culkin was a direct result
o
the Scientology defendants public misuse
o
confidential information.
Mr
Culkin demanded a public apology from the Scientology defendants. Instead
o
making an apology, they have continued
to
publicly misstate and mischaracterize his position. After being thrust against his will into this suit by the Scientology defendants, he understandably rebuffed their request for him to testify on their behalf. I am writing to make clear, in response
to
the Scientology defendants motion, that Mr. Culkin will appear to testify,
in
court or at deposition, as a reluctant, but independent witness. Any party may subpoena him or,
i
the Scientology defendants agree, he will appear voluntarily. Contrary to the Scientology defendants motion,
Mr.
Culkin
is
willing to travel to Florida
i
his reasonable expenses are paid.
We
request that the parties or the Court allocate the expenses in such a way that
no
party may be said to
be
influencing his testimony. We await your response. Very truly yours,
