UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
LUIS A. GARCIA SAZ and wife, MARIA DEL Case No. 8:13-CV-220-T27 TBM
ROCIO BURGOS GARCIA,
Plaintiffs,
vs.
CHURCH OF SCIENTOLOGY RELIGIOUS
TRUST, et al.;
Defendants.
                                                                ~ /
PLAINTIFFS' RESPONSE TO DEFENDANTS' MOTION FOR LEAVE TO
FILE AUTHENTICATED COPY OF COMPLETE 1963 HCO POLICY LETTER
Plaintiffs, LUIS A. GARCIA SAZ and MARIA DEL ROCIO BURGOS GARCIA, by
and through their undersigned attorneys, file this response to Defendants ' Motion for Leave to
File Authenticated Copy of Complete 1963 HCO Policy Letter [D.E.# 127] and state:
1. Plaintiffs are reluctant to object to the introduction of the authenticated copy of the
complete 1963 HCO policy letter because even a cursory review of it shows that the so-called
Rules of Committee of Evidence has zero to do with arbitration, which is not even mentioned in
the letter.
In fact, the procedure for a Committee of Evidence couldn' t possibly be used in
arbitration.
• The Committee is convened by a convening authority, not the parties.
• The subject matter of the jurisdiction of the Committee is punishment, not
fraudulent donations.
Case 8:13-cv-00220-JDW-TBM Document 128 Filed 09/24/14 Page 1 of 4 PageID 2927
• It is composed of an appointed chainnan, appointed secretary and 2 - 5 members
all appointed by the convening authority, not three Scientologists in good standing
chosen by the parties.
• Its findings can be altered or nullified by the convening authority who "approves,
mitigates or disapproves the findings" and may, at any time, simply disband the
Committee (Page 3).
• The ultimate authority for reviewing the findings of a Committee of Evidence is
L. Ron Hubbard who has been dead for 28 years (Page 7).
It is, in fact, exquisite proof of the absence of arbitration rules and is understandably
never mentioned in the Arbitration Agreement.
2. The problem with allowing the Defendants to put in this letter after hearing additional
evidence is:
• It is too late to add evidence.
• The hearing was nonevidentiary.
• It invites further argument.
• Plaintiffs attempted to place this letter and affidavits concerning it at the time the
Defendants responded to this Court's Order of October 18, 2013 [D.E.# 89] and
Defendants successfully objected and moved to strike that evidence which
resulted in this Court's Order [D.E.# 98] of November 13, 2013, striking the very
same information.
• This Court already ruled at the hearing that this letter was inadmissible at a
nonevidentary hearing.
Case 8:13-cv-00220-JDW-TBM Document 128 Filed 09/24/14 Page 2 of 4 PageID 2928
• If admitted, in fairness, Plaintiffs' affidavits and exhibits stricken at Defendants
requests should be admitted in rebuttal.
WHEREFORE, Plaintiffs respectfully request that this Court deny Defendants' Motion to
file an authenticated copy of the complete 1963 HCO policy letter.
Dated: September ~ 3 , 2014
Respectfully submitted,
~ A ~ ~
  ~
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
tedbabbitt@babbitt-johnson-.com
-and-
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 Blvd.
Miami, FL 33131
Phone: 305-372-5352
Fax: 305-372-5355
RPW @weillaw .net
amcgovern@weillaw.net
Counsel for Plaintiffs Luis A. Garcia Saz and
Maria Del Rocio Burgos Garcia
Case 8:13-cv-00220-JDW-TBM Document 128 Filed 09/24/14 Page 3 of 4 PageID 2929
CERTIFICATE OF SERVICE
We hereby certify that, on   2014, 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 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
eodore Babbitt
F. Wallace Pope, Jr. , Esq.
FBN 124449
Johnson Pope Bokor Ruppel
& Bums, LLP
911 Chestnut Street
Clearwater, FL 33757
Phone: (727) 461-1818
Fax: (727) 462-0365
E-mail: wallyp@ipfirm.com
Counsel for Flag Church & Ship
Church
Of Counsel:
Eric Lieberman
Rabinowitz, Boudin, Standard, Krinsky
& Lieberman, P.C.
Suite 1700
45 Broadway
New York, NY 10006
(212) 254-1111
Marie Tomassi, Esq.
FBN 772062
Trenam Kember Scharf Barkin Frye
O'Neill & Mullis, P.A.
Bank of America Building
200 Central A venue, Suite 1600
St. Petersburg, FL 33701
Phone: (727) 820-3952
Fax: (727) 820-3972
E-mail: mtomassi@trenam.com
Counsel for lAS Administrations, Inc.
And U.S. lAS Members Trust
Nathan M. Berman, Esq.
FBN 329230
E-mail: nberman@zuckerman.com
Lee Fugate, Esq.
FBN 170928
E-mail: lfugate@zuckerman.com
Jack E. Fernandez, Esq.
FBN 843751
E-mail : jfemandez@zuckerman.com
Mamie V. Wise, Esq.
FBN 65570
E-mail: mwise@zuckerman.com
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
Case 8:13-cv-00220-JDW-TBM Document 128 Filed 09/24/14 Page 4 of 4 PageID 2930