CAUSE NO. C2013-1082B MONIQUE RATHBUN Plaintiff
VS.
DAVID MISCAVIGE RELIGIOUS TECHNOLOGY CENTER CHURCH OF SCIENTOLOGY INTERNATIONAL STEVEN GREGORY SLOAT and MONTY DRAKE Defendants.
IN THE DISTRICT COURT
207
T
JUDICIAL DISTRICT COMAL COUNTY, TEXAS
DECL R TION OF D VID MISC VIGE IN SUPPORT OF SPECI L PPE R NCE
My name is David Miscavige, my date of birth is April 30, 1960, and my address is 1710
Ivar Ave. Los Angeles California 90028.
1
I am, and since 1987 have been, the Chairman of the Board of Religious
Technology Center ( RTC ). RTC is a religious non-profit California corporation that is tax
exempt under IRC § 501(c)(3) and a church of the Scientology religion. RTC is located at 1710
Ivar Ave. Suite 1100 Los Angeles CA.
2.
I am the ecclesiastical leader of the Scientology religion.
3.
I am a resident of California. I have a California driver's license and I am
registered to vote and have been periodically summoned for jury duty in California. I have never
had a Texas driver's license and have never been registered to vote or eligible for jury duty in
Texas.
4.
I have never been a resident of the State of Texas. I have never had an office in
Texas nor have I ever had a Texas telephone number. I have never had a Texas bank account and have never owned real property in Texas.
David Miscavi
5.
I do not have any employees, servants, or agents in Texas and I have never
committed a tort in whole or in part in Texas. I also have not contracted by mail, or otherwise,
with a Texas resident where either party is to perform the contract in whole or in part in the State
of Texas. I have never recruited a Texas resident, directly or through an intermediary located in
Texas for employment inside or outside of Texas.
6.
I have never availed myself of the privilege of conducting activities within the State of Texas. I have not made any purposeful contacts with the State of Texas seeking any
benefit advantage or profit and have not otherwise availed myself of the benefits and protection of Texas law.
7.
I have been in Texas once in the last 25 years. In April 2009 I traveled to Texas to
officiate at the opening of the new Church of Scientology of Dallas. I was in Dallas for two
days.
8.
Prior to learning of this lawsuit, I had never heard of nor did I have any
knowledge of Defendants Mr. Sloat and Mr. Drake. I was not involved in the hiring, directing,
instructing or communicating with Mr. Sloat Mr. Drake or anyone else relating to the allegations
asserted in this lawsuit.
I declare under the penalties of perjury of the states of Texas and California that the
foregoing is true and correct. Executed in the United States of Ame
f California on t
h
day of August, 2013.
2
