UNITEDSTATEDISTRICTCOURTMIDDLE

DISTRICT

OF

FLORIDATAMPA

DIVISIONLUIS

A.

GARCIA

SAZ

and

Wife,

MARIA

DELROCIOBURGOS

GARCIA,Plaintiffs,

vs.CHURCH

OF

SCIENTOLOGYFLAG

SERVICE

ORGANIZATION,INC.,and

CHURCHOF

SCIENTOLOGY

FLA

SHIPSERVICE

ORGANIZATION,

INC.Defendants.

Case

No:

8:13

-cv

-220-T27

TBM

I

AFFIDAVIT

OF

LUIS

A.

GARCIASAZ

STATE

OF

CALIFORNIA

COUNTYOF

ORANGE

BEFOREME,

the

undersigned

authority,

personallyappeared

LUTS

A.

GARCIA

SAZ,

who,first

being

sworn,

deposesand

says:My

name

is

Luis

A.

Garcia

Saz.

I

amover

21

years

of

age.

We

had

asked

for

a

court

reporter

to

be

present

duringthearbitration

so

there

would

bearecord

of

the

proceedings

(Dkt.

257).

This

motion

was

denied

(Dkt.

265).

I

have

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Affidavit

of

Luis

A

Garcia

-Saz

 

1

EXHIBIT

3

Case 8:13-cv-00220-JDW-TBM Document 270-3 Filed 01/19/18 Page 1 of 52 PageID 4561

 

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thereforeprepared

this

affidavit

summarizingthe

arbitration

to

thebest

of

my

ability.

I

am

competent

to

testif'

and

have

personalknowledge

of

thefacts

 

contained

in

thisaffidavit.

Pursuant

to

the

Orders

to

submit

to

arbitration

in

the

abovenamed

case

(Dkt.

189,

198,

215,

225,

254,

265)

Plaintiffs

havecompliedand

now

writethe

following

affidavit

supporting

their

Motion

to

Vacate

theArbitration

Award:

October

23

2017

My

wife

Maria

and

I

arrived

at

around

8:45

amonOctober

23,

2017,

to

theindicatedaddress.Thedriveway

hadbeen

blockedwitha

row

of

white

cones

andthere

were

three

security

personnelguarding

the

driveway

entrance.

One

of

the

guardsapproachedourcarand

greetedus.

I

explained

wewere

herefor

a

meetingwith

Mr.

Mike

Ellis.He

asked

for

our

names

and

our

personal

identification.

My

wifeMaria

and

I

showedhim

our

driver's

licenses.

I

then

explained

to

the

guard

that

PaulineLombard

(theperson

in

the

car

right

behindus)

was

also

with

us.

I

explained

that

she

was

here

to

assist

me

with

my

reading

due

to

my

visual

issues,

as

I

have

an

eyesight

medical

condition

which

makesreading

extremely

difficult,

tedious,

and

tiring.

The

security

guardchecked

his

papers

and

he

said She

is

not

onthe

guest

list.

I

reiteratedthat

I

needed

Ms.

Lombard

to

attendthe

meeting

with

us,

but

the

guard

refused

to

even

let

heraccessthe

parking

lot.

I

then

got

out

of

mycar,

went

Affidavit

of

Luis

A

Garcia-5az

 

Case 8:13-cv-00220-JDW-TBM Document 270-3 Filed 01/19/18 Page 2 of 52 PageID 4562

 

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to

Ms.

Lombard's

car,and

askedher

to

park

nearby

and

wait

for

me.

I

toldher

I

would

gointo

the

buildingand

speak

with

Mr.

Ellisaboutmy

need

for

her

help.

Subsequently,

Maria

and

I

were

allowed

thru

the

driveway.We

entered

the

buildinglobby

and

were

asked

to

sign

in.

At

that

time

I

askedthereceptionist

if

she

couldhave

Mr.

Ellis

come

see

me,

and

mentioned

I

had

Ms.

Lombardwaiting

outside.

I

was

told

Mr.

Elliswould

be

informed.

We

werethentaken

to

a

smallconference

room

just

steps

fromthe

lobby,

andweretold

to

wait.

Mr.

Elliscame

into

the

room

and

introduced

himself.

I

explained

a

person

hadcomewith

me

to

assist

me

infinding

and

handing

me

documents

during

my

presentation

and

to

also

read

them

aloud

as

necessary.

I

told

Mr.

Ellis

that

I

hada

visual

medicalcondition

whereby

most

times

I

justcouldn't

read.

I

alsohandedhima

letter

from

myophthalmologist

thatvalidated

my

eye

condition

(Attached

to

this

Affidavitas

ExhibitA).

Mr.

Ellis

readtheletterandsaid

Ms.

Lombard

could

not

come

in,

that

she

wasn't

a

party

to

these

proceedings

and

that

he

would

be

happy

to

provide

a

person

to

assist

me

in

anything

I

needed.

I

immediately

pointed

out

that

Ms.

Lombard

and

I

had

spent

aconsiderable

amount

of

time

reviewing

theprinted

materials

I

intended

to

use

to

support

my

case

during

thearbitrationhearing,

andanyother

personwould

not

be

familiar

with

my

presentation

material

and

would

violate

my

confidence.

Mr.

Ellis

reiterated

Ms.

Lombardwould

be

denied

entry.

I

thentold

Mr.

Ellis

I

wanted

to

bring

severalwitnesses

and

needed

to

coordinate

the

timing.He

said

they

would

not

be

allowedbecausetheir

testimonycould

not

possiblybe

confirmed.

Affidavit

of

Luis

A

Garcia

-Saz

 

3

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