1
2
N
THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF OKLAHOMA
NATIONAL ASSOCIATION OF
FORENSIC
3 COUNSELORS, INC., a
Nevada
Non-Profit Corporation;
et
al.,
4
5
6
v.
Plaintiffs, NARCONON INTERNATIONAL, a California 7 Non-Profit Corporation;
et
al.,
8
9 10
Defendants. Case No. 6:14-cv-00187-RAW
DECLARATION OF DAVID MISCAVIGE
N SUPPORT
OF MOTION
TO
12
DISMISS OF DEFENDANT DAVID MISCA VIGE FOR LACK OF PERSONAL
3
JURISDICTION OR ALTERNATIVELY FOR FAILURE
TO
STATE A CLAIM
14
15
I,
David
Miscavige, declare
as
follows:
16
1.
I
am
the Chairman
of the Board
of
Religious Technology
Center
( RTC )
17
and the
ecclesiastical
leader
of
the
Scientology religion. I
am
named
as
a
defendant
in
18
the
above-entitled action,
but
I
contest
this
Court's
personal
jurisdiction over me. I have
19
personal
know edge
of
the
facts
set
forth
herein.
f
called
as
a witness, I could
and
20
would competently
testify to
the
matters
stated
herein.
21
2.
I
was
elected
Chairman
of
the
Board ofRTC
in
1987. RTC is a California
22
non-profit religious corporation
established
to own
the trademarks
associated
with
the
23
Scientology religion.
24
3.
I
am
not,
and
never
have
been, a
resident of
the State
of
Oklahoma
I
live
25
in
California). I own no
property
in
Oklahoma
and
never
have;
rent
no
property
in
26
Oklahoma,
and
never
have;
have
no
assets
in
Oklahoma,
and
never
have; have no home
27
in
Oklahoma,
and
never
have;
have
no office
in
Oklahoma,
and
never
have;
have
no
28
telephone
listing
in
Oklahoma,
and
never
have;
pay
no
taxes
in
Oklahoma,
and
never
424149vl
6:14-cv-00187-RAW Document 454-1 Filed in ED/OK on 10/30/14 Page 1 of 2
1 have;
have
no
bank
account
in
Oklahoma,
and
never
have;
and
am
not registered
to vote 2
in
Oklahoma,
and
never have
been.
3
4.
I
have been
in
Oklahoma
only once,
and
that
was
only for a few
hours
and
4
in
2003. Specifically, I
was
at
the
opening
ceremony of a college facility outside St. 5 Louis,
Missouri
and
after
that
visit was
done, I
stopped
by
the
Narconon
Arrowhead
6
Oklahoma
facility,
was
given a
tour
of
the
facility
and
then
left. My
short time an
7 afternoon)
in
Oklahoma
had
nothing
to
do
with
the
Plaintiffs
in
this lawsuit
or
their
8
purported trademarks.
9 I declare
under
penalty
of
perjury under
the
laws of
the
United States
of
10
America
that
the
foregoing
is
t1;ue
and
correct.
11
Executed
on
ctober~
14.
·
·
12
3
14
15
16 17
18
19
20
21
22
23
24
25
26
27 28
424149vl
6:14-cv-00187-RAW Document 454-1 Filed in ED/OK on 10/30/14 Page 2 of 2
