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DEFS.
CSI
AND
CC’S
MOTION
TO
COMPEL
ARBITRATION
AGAINST
JANE
DOE
#2
SCHEPER KIM & HARRIS LLP
WILLIAM H. FORMAN (State Bar No. 150477)
wforman@scheperkim.com
DAVID C. SCHEPER (State Bar No. 120174)
dscheper@scheperkim.com
MARGARET E. DAYTON (State Bar No. 274353)
pdayton@scheperkim.com
800 West Sixth Street, 18th Floor Los Angeles, California 90017-2701 Telephone: (213) 613-4655 Facsimile: (213) 613-4656 Attorneys for Defendants CHURCH OF SCIENTOLOGY INTERNATIONAL AND CHURCH OF SCIENTOLOGY CELEBRITY CENTRE INTERNATIONAL JEFFER MANGELS BUTLER & MITCHELL LLP SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT
CHRISSIE CARNELL BIXLER; CEDRIC BIXLER-ZAVALA; JANE DOE #1; MARIE BOBETTE RIALES; and JANE DOE #2, Plaintiffs, v. CHURCH OF SCIENTOLOGY INTERNATIONAL; RELIGIOUS TECHNOLOGY CENTER; CHURCH OF SCIENTOLOGY CELEBRITY CENTRE INTERNATIONAL; DAVID MISCAVIGE; DANIEL MASTERSON; and DOES 1-25, Defendants. CASE NO. 19STCV29458
ssigned to Hon.
Steven J. Kleifield, Dept. 57
NOTICE OF MOTION AND MOTION TO COMPEL RELIGIOUS ARBITRATION AGAINST JANE DOE #2 AND FOR STAY OF LITIGATION; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF
[
Concurrently filed with Declarations of Lynn R. Farny and Margaret Marmolejo; and [Proposed] Order
] Hearing Date: March 25, 2020 Time: 8:30 a.m. Dept.: 57
RESERVATION NO.: 934155920815
Action filed: August 22, 2019 Trial date: Not yet set
Electronically FILED by Superior Court of California, County of Los Angeles on 01/06/2020 07:25 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk
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2
DEFS.
CSI
AND
CC’S
MOTION
TO
COMPEL
ARBITRATION
AGAINST
JANE
DOE
#2
TO ALL PARTIES HEREIN AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE THAT on March 25, 2020, or as soon thereafter as the matter may be heard in Department 57 of the above-entitled Court, located at 111 N. Hill Street, Los Angeles, California 90012, Defendants Church of Scientology Celebrity Centre International (“CC”) and Church of Scientology International (“CSI”) will and hereby do move the Court for an order compelling Plaintiff Jane Doe #2 to comply with her written agreements, which require Plaintiff to resolve
“any dispute, claim or controversy” that may arise between them. Those agreements require Plaintiff to litigate the causes of action she alleges in this lawsuit against CC and CSI, if at all, through a religious arbitration. CC and CSI also seek an order staying this matter pending final conclusion of those proceedings.
This Motion is made pursuant to the Federal Arbitration Act and California Code of Civil Procedure Section 1281.2,
et seq
., on the grounds that written agreements to arbitrate the entire controversy exist and that Plaintiff Jane Doe #2 has refused to arbitrate the controversy. By this Notice and Motion, CC and CSI also incorporate the arguments in the Motion to Compel Religious Arbitration filed this date by Defendant Religious Technology Center (“RTC”), and specifically incorporate all arguments and evidence presented by RTC in its Memorandum of Points and Authorities in support of its Motion to Compel Religious Arbitration. This Motion will be and hereby is made on the grounds stated in the Memorandum of Points and Authorities in support of this Motion, as well as the Memorandum of Points and Authorities filed by RTC, the Declarations of Lynn R. Farny and Margaret Marmolejo, and exhibits thereto, the pleadings and other papers filed in this action, and on such other oral and documentary evidence as may be presented at the hearing on this matter.
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3
DEFS.
CSI
AND
CC’S
MOTION
TO
COMPEL
ARBITRATION
AGAINST
JANE
DOE
#2
DATED: January 6, 2020 SCHEPER KIM & HARRIS LLP WILLIAM H. FORMAN By:
/s/ William H. Forman
William H. Forman Attorneys for Defendants Church of Scientology International and Church of Scientology Celebrity Centre International
