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OBJECTIONS TO PLAINTIFF’S EVIDENCE SUBMITTED IN OPPOSITION

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 Defendant, Church of Scientology International

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT

VALERIE HANEY, Plaintiff, v. CHURCH OF SCIENTOLOGY INTERNATIONAL; RELIGIOUS TECHNOLOGY CENTER, and DAVID MISCAVIGE; and DOES 1-25, Defendants. CASE NO. 19STCV21210

 ssigned to Hon. Richard J. Burdge, Jr.,  Dept. 37

DEFENDANT CHURCH OF SCIENTOLOGY INTERNATIONAL’S OBJECTIONS TO PLAINTIFF’S EVIDENCE SUBMITTED IN OPPOSITION TO ITS MOTION TO COMPEL RELIGIOUS ARBITRATION

 

[Filed Concurrently with Reply In Support of  Motion to Compel Religious Arbitration; Supplemental Declaration of Gary S. Soter; Supplemental Declaration of Lynn R. Farny; and Proof of Service]

 

Dept.: 37 Date: January 30, 2020 Time: 8:30 a.m.

RESERVATION NO. 523728976924

Electronically FILED by Superior Court of California, County of Los Angeles on 01/23/2020 06:19 PM Sherri R. Carter, Executive Officer/Clerk of Court, by J. Lara,Deputy Clerk

 

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OBJECTIONS TO PLAINTIFF’S EVIDENCE SUBMITTED IN OPPOSITION

OBJECTIONS TO PLAINTIFF VALERIE HANEY’S EVIDENCE SUBMITTED IN OPPOSITION TO CSI’S MOTION TO COMPEL RELIGIOUS ARBITRATION

Defendant Church of Scientology International (“CSI”) submits the following objections to evidence submitted by Plaintiff Valerie Haney in support of her Opposition to CSI’s Motion to Compel Religious Arbitration.

OBJECTION 1:

Material objected to: “rather than being provided with the minimum compulsory education required under state law.” (Declaration of Valerie Haney In Opposition to Defendant Church of Scientology International’s Motion to Compel Arbitration (“Pl.’s Dec.”) ¶ 2.) Grounds for objection: Lack of foundation (Evid. Code § 403); Lack of personal knowledge (Evid. Code § 702(a)); Improper legal conclusion (Evid. Code § 310).

OBJECTION 2:

Material objected to: “Scientology brainwashed me. . .” (Pl.’s Dec. ¶ 5.) Grounds for objection: Conclusory and unsupported by facts; Lack of foundation (Evid. Code § 403); Irrelevant (Evid. Code § 350;

U.S. v. Fishman

, 743 F. Supp. 713 (N.D. Cal. 1990) (“brainwashing” is not recognized as a scientific concept)).

OBJECTION 3:

Material objected to: “I was never given a choice whether or not to sign the agreements attached to Defendant’s motion.” (Pl.’s Dec. ¶ 7.) Grounds for objection: Conclusory and unsupported by facts; Lack of foundation (Evid. Code § 403); Vague or ambiguous (Evid. Code § 352); Misstates the evidence (Evid. Code §§ 350, 352); Irrelevant (Evid. Code § 350;

Watson v. Jones

, 80 U.S. 679, 729-31 (1871)).

OBJECTION 4:

Material objected to: “Every time I signed a document, including the agreements attached to Defendant’s motion, it was in front of a high-ranking Scientology official. I was not permitted time to review any of these documents. The official who handed me these documents to sign would summarize the contents in their own words and I would then be required to sign with the official standing over me. If I took too long or attempted to read these documents, I would be told

 

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OBJECTIONS TO PLAINTIFF’S EVIDENCE SUBMITTED IN OPPOSITION

‘are you done yet, just sign it.’” (Pl.’s Dec. ¶ 7.) Grounds for objection: Conclusory and unsupported by facts; Lack of foundation (Evid. Code § 403); Vague or ambiguous (Evid. Code § 352); Misstates the evidence (Evid. Code §§ 350, 352).

OBJECTION 5:

Material objected to: “I sometimes asked if I could take these documents home with me to review and I was told that was ‘not possible.’” (Pl.’s Dec. ¶ 7.) Grounds for objection: Conclusory and unsupported by facts; Lack of foundation (Evid. Code § 403); Vague or ambiguous (Evid. Code § 352).

OBJECTION 6:

Material objected to: “When I joined the Sea Org, I was forced to sign a ‘billion-year contract.’ dedicating my life to serving Scientology. From my arrival until my escape, I was forced to live in communal housing and subjected to laborious and back-breaking work for an average of 100 hours per week. I was paid less than fifty dollars per week.” (Pl.’s Dec. ¶ 8.) Grounds for objection: Irrelevant (Evid. Code § 350;

 Katz v. Superior Court 

, 73 Cal. App. 3d 952, 972 (1973);

 Meroni v. Holy Spirit Ass’n

, 506 N.Y.S.2d 174, 176-78 (N.Y. App. Div. 1986);

Watson v. Jones

, 80 U.S. 679, 729-31 (1871)); Conclusory and unsupported by facts; Vague or ambiguous (Evid. Code § 352).

OBJECTION 7:

Material objected to: “I was verbally, physically, and psychologically restricted from leaving Gold Base. I had little to no contact with family or friends, including my husband, throughout my time at Gold Base.” (Pl.’s Dec. ¶ 9.) Grounds for objection: Irrelevant (Evid. Code § 350;

 Katz v. Superior Court 

, 73 Cal. App. 3d 952, 972 (1973);

 Meroni v. Holy Spirit Ass’n

, 506 N.Y.S.2d 174, 176-78 (N.Y. App. Div. 1986)). Conclusory and unsupported by facts; Vague or ambiguous (Evid. Code § 352).

OBJECTION 8:

Material objected to: “Scientology and Sea Org members at Gold Base also heavily censored any and all of my communication with relatives, friends, and the outside world,