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PROSKAUER ROSE

BERT H. DEIXLER, SBN 70614


2 HAROLD M. BRODY, 84927
G. SAMUEL CLEAVER, 17
3 2049 Century Park 32nd
Los Angeles, CA
4 Telephone: 310.557.2900
Facsimile: 31 193
5
KENDRICK MOXON, No.
6 MOXON & KOBRIN
3055 900
7

9
rNTERNATIONAL
10

11
OF THE STATE OF ~.~M.I~11
12
COUNTY OF LOS ANGELES
13

14
LAURA ANN Case No. 411018
15
Plaintiff, Assigned All
16 Honorable Ronald M.
vs. NOTICE OF
17 IDDGMENT
18 RELIGIOUS Complaint
sued herein SAC
19 as Doe AND DOES
2

Defendants.

23

24

25

26

27

28

NOTICE OF ENTRY OF JUDGMENT


8086/21051-006 Currentf19864663v1
TO AND THEIR ATTORNEYS OF

2 NOTICE THAT on June 9, 2010, _,..., ... _... was entered in the above-

3 captioned matter of defendants Church of Scientology and Religious

4 A copy of the judgment is attached hereto.

6
Dated: July 10
7

8
BERT
9 HAROLD M. BRODY
G. SAMUEL
10

11 G. '-'<.U" ......."
Attorneys for Defendant
12 CHURCH OF
INTERNATIONAL
13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

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- 1-
NOTICE OF ENTRY OF JUDGMENT
8086/21051-006 Currentl19864663v1
"
ORIGIN
PROSKAl'ER ROSE LLP
BERT H. DEIXI.ER. SBN 70614
")
HAROLD M. BRUD'{. SBN 84927
]049 CcnlU[\, Park East. 3'::nd Floor
Los Angch.< C1\ 90067 -3:!06
3 Telephone: 310.557.2900 REC'D FILED
Facsimile: 310.557.219)
4 LOS ANGELES SUPERIO COURT
I
I
I
MOXON & KOBRIN MAY 25 2010
I
!
5 KENDRICK L MOXON, SBN 1.2$t'JG G VVINDOW
3055 Wilshire Boulevard. 'Suite <)"~ .WN
6 Los Angeles. California 900 I0
Telephone: (21 487~4468
7 Facsimile: (213) 487-5385
8 Attornevs for Dclcndant
CIIURCH OF SCIENTOLOGY INTERNATIONAL
9
JEfFER. MANGELS. BVTLER & MARMARO LLP
10 MARC MARMARO. SBN
A\'IY LERNER HILL SBN 216:;~8
II 1900 Avcnue of the Starl'. SC\'cmh Floor
Los !\ngde~. Calilomia 90067-4308
12 Telephone: (:; JO~· 203-8080
Fac!{imiie: (310) 203-0567
13
Alwrm:\'s lilr Dclcndan!
14 REI.IGIOrS TECHNOLOG'{ CENTER
15 SlrpEiUOi{ COlfH.T OF THE STATE OF CALIFOI{NIA
16 1-'01{ THE COUNTY OF LOS ANGELES
17

18 LAURA ANN DeCRESCENZO. ) Nt!. BC 411018


By Fax
) I-Ion. Ronald M. Suhigian
19 Plaintiff. )
)
20 v. ) PlUg. 9'!l!'JtI.JUIlGMENT
)
21 CHURCH OF SCIENTOLOGY )
INTERNATIONAl. a corporate entity, .l Action Filed: April 2,2009
RELIGIOuS TECHNOLOGY CENTER. ) SAC filed: February 1, J 0
previously sued herein as Doc No. I. a . )
California Corporation. AND DOES 2 -20. )
)
24 Defendants. ")

25

16

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:------~--------- .
I IPROPOS[DI·JVO(;l\tENT
ThC' J)~mllrrer of DefenJant Chu~ch ofSdenlology International r-CSf"') 10 th~ ,,,,,,,"'H'

Amended Complaint ('"SAC') of Laur'd Ann DeCrescem::o ("'Plainlirf') came on regularly li.lr

Ill'tlring by the Courl on March 18.20 I0, at 8:45 a.m .. Ihe Honorable Ronald 1'.'1.. Sohigian, Judge

4 presiding. Kathryn Darnell, and Kimberly Miller. of I'vtctzger Law Group appeared as

counsel fbr 'Plaintiff, and Harold M. Brody, Esq. Proskaucr Rose LLP and Kendrick L, :Vloxon,

6 Esq. of Moxon & Kobrin appeared as counsel for CSt After considering parties' papers and

7 hearing oral argument. and good cause appearing therefore. the Court sustained Ihe Demurrer in its

R entirety, \·vithoUl to amend. on the ground that the SAC and each cause of action therein. is

<) burred by the applicable statutes of limitations and fails to slate facls sufficient to constitute 1.1

10 cauSe or action. A true and correct copy aftne Iranscript of thc Cou!1' 5 MUTch I&. 20 I 0 hearing

IJ on CSf's Demurrer is attached hereto as Exhibit ;\.

The Demurrcr of Defendant Religious Technology. ("RTC') to Plaintiffs SAC

13 Lamc 011 reglilarly for hearing by the Court on April 30. 2010, <118:40 a,m .. the HI..1I1orahie Ronald
14 Moo Sohigian. presiding. Kimberly Miller. appeared as counsel for Plaintiff and Marc

!:; !'vlarmaro. Esq. of .!cner. :Vlangcls. Butler & Marmara LLP appeared as cOllnsd for RIC After

16 considering the parties' rapers ant! hearing oral argument. and !!ood causc appearing therefore. thc'

17 COllrt sustained Ihe Demurrer in its entirety. without leU\'C to amend. and dismissed the action in

IR its entirely, on the ground that the SAC, and each cause of action lherdn, is barred by

19 applicable statutes of limitations and fails to slate surficicnt to constit1.lte a cause of action. 1\

20 true and correct copy of the transcript of the Courfs April 30,20 I0 hearing on RTCs Demurrer is
21 attached hereto as Exhibit B.

ConsiSlent therewith, the Court hereby renders Judgment in this matter as follows:

D IT IS ORDERED AND ADJUDGED that Plaimifftake nothing by the SAC, and that
Dclcndan!s recover their CO~1s herein in Ihe amount of:

Church of Scientology International $ , PIlt). ()(l. ~


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xhibit A
1 SUPERIOR COURT OF THE STATE OF CALIFORNIA
2 FOR THE COUNTY OF LOS ANGELES

3 DEPARTMENT 41 HON. RONALD M. SOHIGIAN, JUDGE

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5 LAURA ANN DECRESCENZO, 1


)
6 PLAINTIFF, 1
}
7 VS. ) CASE NO. BC~11018
)
.,.~ "
8 CHURCH OF SCIENTOLOGY )
INTERNATIONAL }
9 )
DEFENDANT, )
10
11
12

13
14
THURSDAY, MARCH 18, 2010
15
16
17

18
19 FOR THE PLAINTIFFS: KATHRYN DARNELL,
ATTORNEY AT LAW
20
KIMBERLY MILLER
21 ATTORNEY AT LAW
22 fOR THE DEfENDANTS; HAROLD M. BRODY,
ATTORNEY AT LAW
23
KENDRICK L. MOXON,
24 ATTORNEY AT LAW
REPORTED BY:
25
ANGELA ZARATAN PARADELA
26 OFFICIAL COURT REPORTER
CSR NO. 9659
27
28
1

1 CASE NUMBER; BC41l018


2 CASE NAME: LAURA ANN DECRESCENZO VERSUS
3 CHURCH OF SCIENTOLOGY INTERNATIONAL
4 LOS ANGELES, CALIFORNIA THURSDAY, ~ARCH 18, 2010
5 DEPARTME:NT 41 HON. RONALD M. SOMIGIAN, JUDGE
6 APPEARANCES: (SEE TITLE PAGE.)
7 REPORTER: ANGELA Z. PARADELA, CSR NO. 9659
8 Tn~E: 8:45 A.M.

9
10 (THE FOLLOWING PROCEEDINGS W~RE HELD IN
11 OPEN COURT:)
12
13 THE COURT: DECRESCENZO AGAINST CHURCH OF
14 SCIENTOLOGY, BC411018.
15 MR. BRODY: GOOD MORNING, YOUR HONOR. HAROLD M.
16 BRODY ON BEHALF OF DEFENDANT MOVING PARTY.
n MR. MOXON: GOOD MORNING, YOUR HONOR. KENDRICK
18 MOXON ALSO ON BEHALF OF DEFENDANTS.
19 MS. DARNELL: GOOD MORNING, YOUR HONOR. KATHRYN
20 DARNELL OF METZGER LAW GROUP ON BEHALF OF PLAINTIFFS.
21 MS. MILLER: GOOD MORNING, YOUR HONOR. KIM MILLER
22 ON BEHALF OF THE PLAINTIFFS, METZGER LAW GROUP.
23 THE COURT: ANYTHING FURTHER FROM THE MOVANT?
24 MR. BRODY: YOUR HONOR, OTHER THAN WE ARE PREP~RED

25 TO ANSWER ANY QUESTIONS COURT MAY HAVE, WE ARE PREPARED TO


26 SUBMIT ON THE PAPERS.
27 THE COURT: ANYTHING FURTHER FROM THE PLAINTIFFS?
28 MS. DARNELL: YOUR HONOR, JUST A COUPLE OF POINTS
....
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1 THE COURT; THANK yOU VERY MUCH.

2 (PROCEEDINGS CONCLUDED.)

10
11

12
13

14
15
16
17

18
19
20
21
22

23
24
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27

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1 SUPERIOR COURT OF THE STATE OF CALIFORNIA


2 rORTAE COUNTY OF LOS ANGELES
3 DEPARTMENT 41 HON. RONALD M. SOHIGIAN, JUDGE
4
LAURA ANN DECRESCENZO, )
5 }
PLAINTIFF, }
6 )
VS. ) CASE NO. BC411018
1 )
CHURCH OF SCI!NTOLOGY )
8 INTERNATIONAL, ) REPORTER'S
) CERTIFICATE
9 DEFENDANTS, )

10

11
STATE OF CALIFORNIA
12 S5
COUNTY OF LOS ANGELES
13

14 If ANGELA Z. PARADE LA , CSR NO. OFFICIAL REPORTER


15 OF THE SUPERIOR COURT OF THE STATE OF CALIFORNIA, FOR THE
16 COUNTY O~ LOS ANGE:LES, DO HEREBY CERTIFY THAT TH£ FOREGOING
17 PAGES 1 THROUGH 7 COMPRISE A FULL, TRUE, AND CORRECT
18 TRANSCRIPT OF THE TESTIMONY AND PROCEEDINGS HELD ON MARCH 18,
19 2010 IN THE ABOVE-ENTITLED MATTER.

20
21

22 MARCH 19, 2010


23

24
25
26 _____________ , CSR NO. 9659
27 OFFICIAL REPORTER
28
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Exhibit B
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1 St'PSRIOR COURT OF THE STATE: OF CALIFORNIA

2 FOR THE COUNTY OF LOS ANGELES

3 DEPARTMENT 41 HON. RONALD M. SOHIGIAN, JUDGE

5 LAURA ANN DECRESCENZO,


6 PLAINTIFF,
7 VS. CASE NO. BC41101B

8 CHURCH OF SCIENTOLOGY CERTIFIED COpy


INTERNATIONAL
9
DEFENDANT,
10
11

12
13
"~'.
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FRIDAY, APRIL 30, 2010
15
16
17

18
19 FOR T~E PLAINTIFFS: KIMBERLY MILLER
ATTORNEY AT LAW
20
Foa THE DEfENDANTS: MARC MARMARO,
21 ATTORNEY AT LAW
22
23

REPORTED BY:
25 ANGELA ZARATAN PARADE LA
OFFICIAL COURT REPORTER
26 CSR NO: 9659
,- . '\ 27

28

Ex (3
1

1 CASE NUMBER: BC411ina


2 CASE NAME: LAURA ANN DECRESCENZO VERSUS

3 CHURCH OF SCIENTOLOGY INTERNATIONAL

4 LOS ANGELES, CALIFORNIA FRIDAY I APRIL 30. 2010


5 DEPARTMENT 41 HON. RONALD M. SOHIGIAN, JUDGE

6 APPEARANCES: {SEE TITLE


7 REPORTER: ANGELA Z. PARADELA, CSR NO. 9659

S TIME: 8:40 A.M.

10 (THE FOLLOWING PROCEEDINGS WERE HELD IN


11 OPEN COURT: j
12

13 THE COURT: OUY. LET' S PICK UP DECRESCENZO


14 AGAINST CHURCH OF SCIENTOLOGY, BC411018.
15 MS. MILLER: GOOD MORNING, YOUR HONOR. KIMBERLY
16 MILLER FOR THE PLAINTIFFS FROM THE METZGER LAW GROUP.
17 MR. MARMARO: GOOD MORNING I YOUR HONOR. MARK

18 MARMARO FOR RELIGIOUS TECHNOLOGY CENTER, MOVING PARTY.


19 THE COURT: ANYTHING FURTHER FROM THE DEMURRANT?
20 MR. M.AR.MAR.O: NOTHING OTHER THAN TO ANSWER COURT'S
21 QUESTIONS AND TO RESPOND.
22 THE COURT: IS THE STATE OF RECORD, COUNSEL FOR THE
23 PLAINTIFF, THAT NO WRITTEN OPPOSITION WAS TIMELY SERVED OR
24 FILED?
25 MS. MILLER: NO,. YOUR HONOR. WE FILED AN
26 OPPOSITION.
27 THE COURT: DATE?
28 MS. MILLER: APRIL 16, 2010.
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1 THE COURT: LET'S SEE.

2 I DON'T HAVE ANY SUCH DOCUMENTS. THAT'S THE

3 REASON WHY I ASKED YOU ABOUT IT. IT' S NOT REALLY HARD TO
4 UNDERSTAND WHY, ASSUMING THAT THEY WERE FILED ON THE DATE

5 THAT 'lOU SAY. JUST -- LET ME 00 A LITTLE BIT OF ADDITIONAL

6 WORK.

7 MR. MARMARO: YOUR HONOR, I SHOULD SAY WE TIMELY

8 RECEIVED THE OPPOSITION.


9 THE COURT: NO. I MEAN, I AM NOT QUARRELING WITH

10 THAT ASSERTION YET. ALL I SAID WAS I DON'T HAVE IT.

11 MR. MARMARO: NO, I UNDERSTAND. I JUST WANT TO

12 MAKE CLEAR, YOUR HONOR, THAT WE RECEIVED IT.

13 THE COURT: NO, I DON'T HAVE THE MATERIAL. I HAVE


14 TO SEE WHAT I CAN GENERATE BY COMPUTER SEARCH', JUST A

15 MINUTE.

16 MS. M!LLER: YOUR HONOR, tiE ARE WILLING TO SUBMIT


17 ON THE -- ON THE WRITINGS. I DO HAVE A CONFORMED COPY. I
18 WOULD BE HAPPY TO GO MAKE A COPY.

19 THE COURT: YOUR POSITION IS DEFENDANT IS

20 ESSENTIALLY DISTINGUISHABLE FROM THE POSITION OF THE OTHER

21 DEFENDANT AND PERHAPS THE WHOLE THING OUGHT TO BE TERMINATED.


22 SO IF THOSE ARE MY VIEWS, SOMEBODY CAN GET TO THE APPELLATE
23 COURT?

24 MS. MILLER: THAT'S VERY WELL AND SUCCINCTLY

25 STATED. BETTER THAN WHAT I WOULD HAVE SAID.


26 THE COURT: I CAN UNDERSTAND THAT WOULD BE AN
27 ENTIRETY RESPONSIBLE WAY TO DO WITH IT. I THINK I AM MAKING
28 THE DECISION THAT'S REQUIRED BY LAW AND THAT CHANGE COULD

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1 ONLY BE MADE BY AN APPELLATE COURT. I THINK I'M BOUND TO DO


2 WHAT I HAVE SUGGESTED. JUST A SECOND.
3 fA PAUSE IN THE PROCEEDINGS.)
4 THE COURT: I THINK WHAT I'M GOING TO DO IS THIS.

5 THE RECORD DOES REFLECT THAT, NOT THE RECORD I HAVE IN HAND,
6 BOT THE COMPUTER-MAINTAINED RECORD DOES REFLECT ON THE 16TH

7 OF APRIL, 2010, MR. VAN SICKLE'S OFFICE -- OR MR. METZGER'S


8 OFFICE, OR BOTH, FILED A DOCUMENT ENTITLED "PLAINTIFF'S
9 MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO
10 DEFENDANT RELIGIOUS TECHNOLOGY CENTER'S DEMURRER TO
11 PLAINTIFF' S SECOND AMENDED COMPLAINT." THAT WAS FILED ON
12 THAT DATE. IT DOES PROPERLY SHOW TODAY NOW THE HEARING
13 DATE, TIME, AND SO FORTH.
14 AND IF YOU WILL WAIT FOR JUST A SECOND.

15 THE ARGUMENTS MADE IN THERE ARE SUBSTANTIALLY


16 SIMILAR TO THE ~~GUMENTS MADE IN CONNECTION WITH THE MATTER
17 THAT WAS DECIDED ON THE 18TH OF MARCH, 2010.
18 JUST A SECOND.
19 AND THE COURT HAS STATED THE STRATEGIC
20 POSITION OF THE PLAINTIFF AS TO WHICH COURT HAS NO RESENTMENT
21 OR SENSE OF VANITY.
22 THE DEFENDANT IT SEEMS TO ME, CORRECT THAT
23 THE PLAINTIFF ENTITLED IS TAKE THB MATTER TO THE APPELLATE
24 COURT.
25 AND WHAT I'M GOING TO DO IS THIS. I WILL
26 DECIDE THE MATTER NOW, AND I WIL~ MAKE A RELATIVELY LONG
27 STATEMENT ON THE RSCORD STATING MY REASONING SO THAT YOU CAN
28 HAVE A RECORD AND THEN TODAY I THINK WHAT I WILL DO IS, IF
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1 IT'S ALL RIGHT WITH THE PLAINTIFF, ON MY OWN MOTION, I WILL

2 SIMPLY DISMISS THIS ACTION IN ITS ENTIRETY -- THAT SHOULD

1 GIVE YOU A TARGET THAT CAN BE ATTACKED ON APPEAL - - AND HAVE

4 THE CLERK PREPARE AN ORDER ACCOMPLISHING THAT FOR MY

5 SIGNATURE.
{} DOES THAT SOUND OKAY FROM THE PLAINTIFF'S

7 POINT OF VIEW?

8 MS. MILLER: YES, YOUR HONOR.

MR. MARMARO: YES. YOUR HONOR.

10 THE COURT: LET'S SEE IF WE CAN DO THAT.

11 ALL RIGHT. THIS IS A LAi'ISUIT THAT WAS FILED

12 ON THE 2ND OF APRIL, 2009 -- THAT DATE IS SIGNIFICANT FOR

13 REASONS THAT WILL BECOME CLEAR LATER -- IN WHICH


14 MS. DECRESCENZO, THE PLAINTIFF, ASSERTS A VIOLATION OF

15 CONSTITUTIONAL RIGHTS, PERSONAL RIGHTS, RIGHTS IN CONNECTION


16 WITH WAGE AN HOUR. AND ESSENTIALLY THE NARRATIVE GIVEN IN

17 THE SECOND AMENDED COMPLAINT IS THAT SHE ASSERTS THAT SHE

18 WAS, r'D SAY, BASICALLY BRAINWASHED. SHE ALLEGES THAT SHB

19 WAS CONTROLLED AND EXPLOITED AS A MEMBER AND EMPLOYEE OF THE

20 SCIENTOLOGY CHURCH BETWEEN THE AGES OF 12 AND 25.

21 AND IN THE SECOND AMENDED COMPLAINT THE

22 PLAINTIFF ASSERTS THE RIGHT TO RECOVERY BASED ON THE THEORIES


23 OF FORCED ABORTION IN VIOLATION OF ARTICLE I, SECTION 1 OF

24 THE CALIFORNIA CONSTITUTION, FORCED ABORTION IN VIOLATION OF

25 COMMON LAW, DEPRAVATION OF LIBERTY IN VIOLATION OF ARTICLE I,

26 SECTION 1 OF THE CALIFORNIA CONSTITUTION, FALSE IMPRISONMENT,


27 INTENTIONAL -- INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS,
26 VIOLATION OF LABOR CODe SECTIONS 970 AND 1194, AND VIOLATION
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1 OF BOSINESS AND PROFESSIONS CODE 17200.


2 THE PLAINTIFF HAS DEMANDED IN HER SECOND

3 AMENDED COMPLAINT A TRIAL BY JURY, ALTHOUGH QUITE OBVIOUSLY


4 THE WAY THE SECOND AMENDED COMPLAINT IS SET UP. SHE WOULD NOT
5 BE ENTITLED TO A JURY AS TO PURPORTED CAUSE OF ACTION 7 WHICH
6 MIGHT - WHICH S~OULD BE TRIED FlRST SEPARATELY AND WITHOUT

7 JURY.
S ON THE 30TH OF MARCH, 2010, AFTER I HAD MADE

9 THE ORDER OF MARCH 1S, 2010, DEFENDANT RELIGIOUS

10 TECHNOLOGY CENTER FILED PAPERS IN SUPPORT OF ITS DEMURRERS TO


11 THE SECOND AMENDED COMPLAINT.
12 THE THRUST OF THE CONTENTION PRESENTED BY
13 THOSE PAPERS IS THAT ALL OF THE PURPORTED CAUSES OF ACTION,
14 ALL SEVEN OF THEM, COULD NOT STATE FACTS SUFFICIENT TO
15 CONSTITUTE A CAUSE OF ACTION BECAUSE THEY ARE ALL TIME BARRED
16 AND BECAUSE THEY DISCLOSE THAT THE PLAINTIFF WAS NOT EMPLOYED
17 BY DEFBNDANT RELIGIOUS TECHNOLOGY CENTER.
IS NOW, WHAT I HAVE ~- WHAT I DID ON THE 16TH OF
19 MARCH, 2010, WAS ~O RULE ON THE POINTS RAISED BY THE
20 DEFENDANT CHURCH OF SCIENTOLOGY IN -- IN FAVOR OF THE
21 DEFENDANT CHURCH OF SCIENTOLOGY AS A MATTER OF LAW. I
22 INDICATE THAT I DONtT HAVE ANY PERSONAL PREFERENCES ONE WAY
23 OR THE OTHER AMONG· THESE VARIOUS LITIGANTS, BUT I DID SUSTAIN
24 THE DEMURRER OF THE CHURCH OF SCIENTOLOGY AND ORDERED THAT
25 THE MATTER SHOULD BE DISMISSED.
26 I AM GRANTING THE REQUEST OF THE DEFENDANT
27 BEFORE ME NOW, RELIGIOUS TECHNOLOGY, FOR JUDICIAL NOTICE, AND
28 I HEREBY SUSTAIN THE CAUSES OF ACTION -- THE DEMURRERS OF
2(

1 DEFEND~' RELIGIOUS TECHNOLOGY TO ALL THE CLAIMS AND

2 PURPORTED CAUSES OF ACTION SET OUT IN THE SECOND AMENDED

3 COMPLAINT BECAUSE THEY DO NOT STATE FACTS SUFFICIENT TO

4 CONSTITUTE A CAUSE OF ACTION AND DENY LEAVE TO AMEND SO THAT

5 PART OF THIS ORDER WILL BE AN ORDER DISMISSING THIS ACTION IN

6 ITS ENTIRETY WITH THE DEFENDANTS TO HAVE THEIR COST OF SUIT

7 HEREIN IN THE AMOUNT OF: DOLLAR SIGN, BLANK, AS TO EACH


8 DEFENDANT,
9 THE VIEW I HAVE, WHICH IS CONFIRMED BY THE

10 PLAINTIFF'S LAWYER, IS THAT THERE IS NO BASIS TO DISTINGUISH


11 BETWEEN PLAINTIFF'S CLAIMS AGAINST DEFENDANT CHURCH OF
12 SCIENTOLOGY AND AGAINST DEFENDANT RELIGIOUS TECHNOLOGY CENTER
13 FOR THE PURPOSE OF THE TIME BAR POINT.
14 AND THE PLAINTIFF RECOGNIZES THAT, AND

15 PLAINTIFF'S VIEW IS I WAS WRONG ON THE 18TH OF MARCH AND I


16 RESPECT THAT VIEW, ALTHOUGH I DON'T AGREE WITH IT -- BUT
17 PRECISELY THE SAME REASONING APPLIES.
18 THIS IS THE SITUATION THAT WE HAVE IN
19 CONNECTION WITH THE DELAYED DISCOVERY RULE WHICH IS ONE OF
20 THE PRINCIPLES ON THE BASIS OF WHICH THE PLAINTIFF CLAIMS
21 THAT THE CASE IS NOT TIME BARRED.
22 THE WAY THAT DELAYED DISCOVERY RULE WORKS IS
23 THAT THE PLAINTIFF DOES NOT NEED TO BE AWARE OF SPECIFIC
24 FACTS NECESSARY TO ESTABLISH THE CLAIM FOR THE LIMITATION
25 PERIOD TO RUN. AND EVEN IF THE PLAINTIFF IS IGNORANT OF THE
26 LEGAL SIGNIFICANCE OF KNOWN FACTS OR OF THE IDENTITY OF THE
27 WRONGDOER, THAT DOES NOT DELAY THE RUNNING OF THE TIME BAR
28 PERIOD. THE -- THE TEST IS AN OBJECTIVE TEST.
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1 THE DISCOVERY RULE LOOKS NOT TO WHAT A


2 PARTICULAR PLAINTIFF ACTUALLY KNEW OR SAYS HE OR SHE KNEW,

3 BUT RATHER WHAT A REASONABLE INQUIRY WOULD HAVE REVEALED.

4 AND THE LIMITATION PERIOD BEGINS TO RUN WHEN THE


5 CIRCUMSTANCES ARE ENOUGH TO GIVE RISE TO A SUSPICION OF
6 WRONGDOING, THAT IS, WHEN THE PLAINTIFF HAS NOTICE OF, OR
7 INFORMATION OF, CIRCUMSTANCES SUFFICIENT TO PUT A REASONABLE

8 PERSON ON INQUIRY.
9 THIS IS DISCUSSED IN A NUMBER OF CALIFORNIA
10 CASES. ONE THAT'S CONVENIENT IS THE MTT.T,~ CASE AT 108
11 CALIFORNIA ~J.A 4TH 625. THE LANGUAGE I HAVE

12 PARAPHRASED SOMEWHAT IS AT 1648 TO 1649.


13 THE PLAINTIFF DOESNIT QUARREL MUCH WITH THAT.
14 HER ARGtJMENT IS THAT SHE HAS PLEADED SUFFICIENT FACTS TO SHOW
15 THAT ACCRUAL OF THE CLAIMS OR COMMENCEMENT OF THE RUNNING OF
16 THE LIMITATIONS PERIOD WAS TOLLED, THAT IS, DELAYED BECAUSE
17 SHE WAS INCAPABLE OF COMPREHENDING THE WRONGFULNESS OF
18 DEFENDANT'S CONDUCT BECAUSE SHE WAS, SHE SAYS, ENMESHED IN A
1~ CONFIDENTIAL RELATIONSHIP WITH DEFENDANT AND WAS BRAINWASHED.
20 AND THIS CONFIDENTIAL RELATIONSHIP POINT IS
21 ALLEGED IN SECOND AMENDED COMPLAINT PARAGRAPH NUMBER -- JUST
22 A SECOND -- MAINLY PARAGRAPH NO. 17, WHICH GOES ON FOR A
23 NUMBER OF SUBPARAGRAPHS. SO -- PARDON ME .-- THE EXISTENCE OR
24 NONEXISTENCE OF A CONFIDENTIAL RELATIONSHIPS PLAYS THE
2S FOLLOWING ROLE IN THE TIME BAR ANALYSIS.
26 THE GENERAL RULES RELATING TO PLEADING AND
27 PROVING FACTS EXCUSING LATE DISCOVERY OF, LET'S SAY,
28 SOMETHING LIKE FRAUD, ARE APPLICABLE EVEN WHEN THERE'S A
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1 CONFIDENTIAL RELATIONSHIP. BOT IN THE CONFIDENTIAL

2 RELATIONSHIP SITUATION, THE DUTY TO INVESTIGATE MAY ARISE

3 LATER BECAUSE THE PLAINTIFF IS ENTITLED TO RELY ON THE

4 ASSUMPTION THAT THE PLAINTIFF'S FIDUCIARY IS ACTING IN THE

5 PLAINTIFF'S BEHALF.
6 BUT ONCE THE PLAINTIFF BECOMES AWARE OF FACTS

7 WHICH WOULD MAKE A REASONABLY PRUDENT PERSON SUSPICIOUS, THE

8 DUTY TO INVESTIGATE ARISES AND THEN THE PLAINTIFF IS CHARGED

9 WITH KNOWLEDGE OF THE FACTS WHICH WOULD HAVE BEEN DISCOVERED

10 BY THAT KIND OF INVESTIGATION.


11 AND THIS IS DISCUSSED IN A NUMBER OF CASES,
12 TOO, ONE OF WHICH IS ~~~ B-E-D-O-L-L-A. IT'S REPORTED
13 AT S2 CALIFORNIA APPELLATE 3D lIS, PRINCIPALLY AT 130 TO 131.
14 SO THE POINT IS EVEN THOUGH THERE IS A
IS FIDUCIARY RELATIONSHIP, A DUTY ARISES INDEPENDENTLY OF A
16 PARTICULAR PLAINTIFF'S SUBJECTIVE STATE OF KNOWLEDGE.
17 NOW, WE GO TO THE - - AND THERE'S MORE LANGUAGE
18 IN THE ~~~ CASE THAT I REFERRED TO PREVIOUSLY.
19 NOW, WHAT WE HAVE IN THIS PLEADING IS THAT
20 PARAGRAPHS 18, 34, 48, 60, 76, 97, AND 111 OF THE SECOND
21 AMENDED COMPLAINT, THE PLAINTIFF ADMITS THAT SHE KNEW SHE WAS
22 IN A BAD SITUATION AND THAT SHE WAS BEING WRONGED WHILE UNDER
23 THE DEFENDANT'S CONTROL UP UNTIL 2004. IN FACT, THE
24 PLAINTIFF HAS THIS ALLEGATION "BROKEN AND FEARFUL OF THE
25 CONTINUED STAY IN THE RPF." PLAINTlFF COULD NO LONGER
26 TOLERATE LIVING AND WORKING AT DEFENDANT'S FACILITIES AND
27 DETERMINED SHE HAD TO ESCAPE, GET OUT OF DEFENDANT'S
28 FACILITIES AT THE END OF HER EMPLOYMENT AND HAD FAKED
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1 SUICIDE.
2 PLAINTIFF ALLEGES THAT SHE BELIEVED THAT IF

3 SHE EXERCISED HER RIGHT OF LIBERTY AND ATTEMPTED TO LEAVE


4 RPF, DEFENDANTS WOULD RETALIATE AGAINST HER. AND THATIS
5 SECTION 44. IN'SECTION 55 SHE SAID -- SHE SAYS SHE AGAIN
6 DECIDED THAT SHE DID NOT WANT TO BE THERE AND ASKED TO LEAVE.
7 PLAINTIFF WAS NOT ALLOWED TO LEAVE BUT INSTEAD, DEFENDANTS
8 MADE PLAINTIFF STAY UP FOR HOURS ON END AND THREATENED,
9 INTIMIDATED, AND COERCED PLAINTIFF INTO STAYING AT THE RPF.
10 THAT S SECTION 55.
I SO PLAINTIFF KNEW THAT SHE WAS BEING HELD
11 AGAINST HER WILL.
12 THEN WE GO TO PARAGRAPHS 19, 35, 49, 61, 77,
13 98, AND 112. IN THOSE SECTIONS PLAINTIFF ALLEGES THAT SHE
14 WAS ALLOWED TO LEAVE RPF - - "RPP" MEANS REHABILITATION
15 PROJECT FORCE - - BUT SHE WAS MADE TO SIGN DOCUMENTS RELEASING
16 ANY CLAIMS THAT SHE HAD AGAINST DEFENDANTS REQUIRING HER TO
17 KEEP CERTAIN INFORMATION CONFIDENTIAL.
18 SHE SAYS THAT -- SHE ALLEGES THAT FROM 2004
19 AND JULY OF 2008, SHE BELIEVED THAT BY SIGNING THOSE
20 DOCUMENTS, SHE DIDN'T HAVE ANY CLAIM OR RIGHTS AGAINST THE
21 DEFENDANTS. THIS IS PARAGRAPHS 21, 37, 51, 63 -- JUST A
22 SECOND.
23 MS. MILLER: EXCUSE ME, YOUR HONOR. I WOULD BEG
24 mE COURT'S INDULGENCE. I AAVE TO CHECK UP IN DEPARTMENT 61.
25 THE COURT: YOU CAN LEAVE IF YOU WANT.
26 MS. MILLER: APOLOGIZE.
27 THE COURT: I'M GOING TO KEEP ON THIS DOING. I
2E1 MEAN YOU'RE l:N A HEARING HERE. BUT IF YOU DON' T WANT TO STAY
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2 MS. MILLER: NO, YOUR HONOR. I UNDERSTAND. I orD

3 ASK THE CLERK AND TOLD THE CLERK THAT I NEEDED TO BE ABLE TO

4 CHECK IN UP --

5 THE COURT: WELL, I'M GIVING YOU PRIORITY. I DON'T


6 gNOW WHAT ELSE I CAN 00. DO YOU W'ANT ME TO TALK FASTER?

MS. MILLER: NO, YOUR HONOR. I VERY MUCH


a APOLOGIZE. I'M JUST TRYING TO NOT OFFEND THIS COURT OR
THE COURT: NO, YOU'RE NOT OFFENDING ME AT ALL.

10 11M JUST -- I MEAN, YOU'RE IN A HEARING HERE AND I HAVE GIVEN


11 YOU PRIORITY. THAT'S WHY YOUR CASE IS BEING CALLED NOW.
THESE OTHER PEOPLE ARE WAITING AROUND. I JUST DON'T KNOW
13 WHAT ELSE I CAN DO FOR YOU.

14 THIS IS A LITTLE BIT LIKE THOSE SCENES IN THE

15 WASTELAND, I GUESS, YOU KNOW, THEY ARE SAYING "TIME, TIME,


16 IT'S TIME," YOU KNOW, BUT I "cAN'T -- I CAN'T -- YOU KNOW, r
17 FEEL LIKE A CHARACTER OUT OF "ALICE IN WONDERLAND." I CAN'T
18 RUN ANY FASTER.
19 MS. MILLER: I UNDERSTAND.

20 THE COURT: ALL RIGHT. OKAY.


21 SO THE PARAGRAPH I WAS GOING TO CHECK WAS
22 PARAGRAPH 79 79, PARAGRAPH 100, PARAGRAPH 114 ALSO RELATE
23 TO THE THING THAT POINT THAT I JUST MADE.
24 BUT AS I HAVE IGNORANCE OF THE LEGAL
25 SIGNIFICANCE OF KNOWN FACTS DOESNIT DELAY THE RUNNING OF THE
26 STATUTE.
27 THEN WE GO TO SECTIONS 96 AND 110.
28 IN THERE THE PLAINTIFF ALLEGES THAT FROM 1991
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1 TO 2004, SHE COULD NOT HAVE REASONABLY DISCOVERED THAT SHE


2 HAD A CLAIM AGAINST DEFENDANTS FOR THEIR FAILURE TO PAY
3 MINIMUM WAGE AND OVERTIME PAY BECAUSE DEFENDANTS DID NOT POST
4 THE "WAGE AN HOUR" NOTICES THAT THEY WERE LEGALLY REQUIRED TO
5 POST_ BUT THERE'S NOTHING THERE ABOUT WHY SHE COULDN'T
6 DISCOVER THAT IN 2004, AFTER SHE GOT OUT OF WHAT SHE, I THINK

7 REFERRED TO AS THE " DEFENDANT , S CLUTCHES."


8 SO THEN WE 00 TO ALLEGATIONS IN PARAGRAPHS 22,

9 38, 52, 64, 80, 110 -- NOT 110 -- IT'S 101, ACTUALLY, AND

10 115.

11 IN THOSE ALLEGATIONS - IN THOSE PARAGRAPHS


12 THE PLAINTIFF CLAIMS ESSENTIALLY THAT IN JULY, 2008, SHE· ..
13 REALIZED SHE MIGHT HAVE LEGAL CLAIMS AGAINST THE DEFENDANTS
14 AND THAT THE DOCUMENTS IN CONFIDENTIALITY CONFIDENTIALITY
15 AGREEMENT SHE WAS COERCED INTO SIGNING IN 2004, WERE
16 POTENTIALLY INVALID BY HAVING DISCOVERED A -- A MINIMIZED WEB

17 PAGE ON A fAMILY MEMBER'S COMPUTER AND TALKING TO HER FAMILY


18 WHO HAD BEEN RESEARCHING THE EXPERIENCE OF EX-SCIBNTOLOGIST
19 FOLLOWERS WHO WERE -- WHO HAVE LIVED AND WORKED AT THE SAME
20 FACILITIES AS PLAINTIFFS.
21 NOW, THIS SEEMS TO ME TO BE AN ADMISSION THAT

22 EVEN IF BY VIRTUE OF A CONFIDENTIAL RELATIONSHIP, THE


23 DEFENDANT HAD A DUTY TO DISCLOSE OR NOT TO CONCEAL
24 WRONGFULNESS OF DEFENDANT I S CONDUCT AND THE POTENTIAL
25 VALIDITY OF PLAINTIFF'S CLAIMS. THERE WAS NO CONCEALMENT BY
·26 'l'HE DEFENDANTS ONCE THE PLAINTIFP LEFT THE RPF IN 2004.
27 I MEAN I HER MOMENT OF REALIZATION CAME THROUGH
28 FAMILY MEMBERS WHO HAD GOTTEN THE INFORMATION OVER THE
2E

12

1 INTERNET, AND THAT FREELY AVAILABLE INFORMATION WAS NOT

2 SOPPRESSED, WAS REASONABLY DISCOVERABLE. CONFERRING WITH

3 FAMILY MEMBERS WOULD HAVE BEEN READILY AVAILABLE TO ANYBODY.


4 SHE CAN CONFER WITH HER FAMILY MEMBERS AT ANY TIME, AND

5 INDEED THERE'S NOTHING SPECIAL ABOUT WHEN SHE DID CONFER WITH

6 THEM. SHE DOESN'T ALLEGE SHE DISCOVERED A FACT WHICH WAS


7 PREVIOUSLY UNAVAILABLE TO HER OR ANYTHING LIKE THAT.
8 SO FROM THIS PLEADING, IT APPEARS THAT THE
9 PLAINTIFF WAS AWARE OF ALL THE FACTS IN 2004, WHICH WOULD

10 MAKE A REASONABLY PRUDENT PERSON SUSPICIOUS WHICH WOULD GIVE


11 RISE TO A DUTY TO INVESTIGATE. THEN SHE WOULD BE CHARGED
12 WITH KNOWLEDGE OF THE FACTS WHICH WOULD HAVE BEEN DISCOVERED
13 BY SUCH AN INVESTIGATION. THAT' S IN THAT ~~~ CASE AT
14 PAGE 131. EVEN IF SHE DID NOT HAVE ANY ACCESS TO THE

15 INTERNET, WHEN SHE LEFT SHE DID HAVE DUTY TO INVESTIGATE THE
16 VALIDITY OF HER CLAIMS - - CONSULTING AN ATTORNEY - - AND SO
17 FORTH.

18 A CONTRACT OBTAINED BY MENACE OR DURESS IS


19 VOIDABLE, NOT VOID, AND THE DEFENSE OF DURESS OR MENACE IS A

20 PERSONAL DEFENSE. IT CAN BE -- IT CAN BE LOST BY FAILURE


21 TIMELY TO AT ~ CALIFORNIA
22 APPELLATE 2D, 573 AT PAGE 578 SAYS THAT.
23 SO THE DELAYED DISCOVERY RULE DOESN'T APPLY AT
24 ANY TIME AFTER 2004. LET'S SAY THAT THE APPLICABLE
2S LIMITATION PERIOD BEGAN TO RON ON JANUAR~ 1, 2005, BOT AS I
26 SAY, THIS CASE WAS FILED ON APRIL 4, 2009. SO ALL THE CLAIMS
27 ARE TIME BARRED.
28 PLAINTIFF CLAIMS THAT EQUITABLE ESTOPPEL
EGAL

13

1 APPLIES TO HER CLAIMS BECAUSE SHE WAS FORCED TO SIGN THESE


2 AGREEMENTS AND SO FORTH. BUT THE MILLS CASE AT 108
3 CALIFORNIA APPELLATE 4TH AT PAGE NO. 62 TALKS ABOUT THAT.
4 J\ND PLAINTIFF WAS NOT LULLED INTO A FALSE

5 SENSE OF SECURITY. ON THE CONTRARY. SHE WAS - - SHE KNEW FROM


6 THE TIME SHE WAS ALLOWED TO LEAVE THAT DEFENDANT WAS PREPARED

7 TO TAKE AN 1\DVERSARIAL POSITION TO HER IN THE EVENT OF A

a FURTHER - - OF A FUTURE LAWSUIT.


9 ONCE NO LONGER UNDER THE ALLEGED OPPRESSION, A
10 REASONABLE PERSON IN PLAINTIFF'S POSITION WOULD HAVE, SHOULD
11 HAVE OBTAINED COUNSEL TO OBTAIN ~~ TO EVALUATE WHETHER
12 PLAtNTIFF HAD ANY LEGAL RECOURSE. SHE -- SO EQUITABLE
13 ESTOPPEL SEEMS TO ME DOES NOT APPLY HERE.
14 THEN THERE IS THIS POINT OF COLLATERAL
15 ESTOPPEL.
16 SHE CONTENDS THAT -- THE PLAINTIFF CONTENDS
17 THAT THE DISTRICT COURT HAS ALREADY RULED THAT THE FOUR-YEAR
18 LIMITATION BEGAN TO RUN WHEN SHE LEFT THE -- THE -- I'M SORRY
19 -- THE DEFENDANT SAYS THAT THE -- THE FOUR-YEAR LIMITATION

20 PERIOD BEGAN TO RUN ON APRIL 8, 2004, AND THAT I'M BOUND BY


21 THAT BECAUSE OF WHAT THE DISTRICT COURT DID.
22 I AM NOT ADOPTING THAT ARGUMENT. THAT WAS NOT
23 A DECISION ON THE MERITS. IN MY VIEW. AND THE CASE ON THAT
24 IS K-O-C-H, 1990, 223 CALIFORNIA APPELLATE 3D, 1591.
25 AND ALSO, COLLATERAL ESTOPPEL DOES NOT APPLY
26 BECAUSE THE DISTRICT COURT JUDGE'S DECISION WAS PART OF THE
27 DECISION IN THIS LITIGATION AND IT IS NOT RENDERED AS PART OF
28 PRIOR LITIGATION. AND THE WAY THAT COLLATERAL ESTOPPEL WORKS
1 IS THAT THERE HAS TO BE A PRIOR CASE WHICH IS CONCLUDED, BUT
2 THE DISTRICT COURT'S DETERMINATION WAS A DECISION IN THIS
3 VERY CASE. SO I'M NOT APPLYING THE COLLATERAL ESTOPPEL
4 POINT.
5 THE COURT DENIES LEAVE TO AMEND. THIS ACTION
6 IS ORDERED DISMISSED IN ITS ENTIRETY. ALL DEFENDANTS ARE
7 AWARDED THEIR COSTS OF SUIT HEREIN IN THE AMOUNT OF; DOLLAR
a SIGN BLANK AS TO EACH DEFENDANT.
9 THE CLERK IS TO PREPARE AN ORDER SO PROVIDING
10 FOR THE COURT'S SIGNATURE. THE COURT WILL·SIGN IT TODAY.
11 AND THE CASE IS ORDERED REMOVED FROM THE ACTIVE LIST.

12 SCHBDULED DATES, IF ANY, ARE ADVANCED AND VACATED.


13 THANK YOU VERY MUCH.
14 MS. MILLER: THANK YOU, YOUR HONOR.
15 MR. MARMARO: THANK YOU, YOUR HONOR.
16 (PROCEEDINGS CONCLUDED.)
17

18

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20

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1 SUPERIOR COURT OF THE STATE OF CALIFORNIA

2 FOR THE COUNTY OF LOS ANGELES

3 DEPARTMENT 41 HON. RONALD M. SOHIGIAN, JUDGE

5 LAURA ANN DECRESCENZO, )


)
6 PLAINTIFF, }
)
7 VS. ) CASE NO. BC41101S
}
8 CHURCH OF SCIENTOLOGY )
INTERNATIONAL, ) REPORTER'S
.9 i CERTIFICATE
DEFENDANTS, )
10

11

12
STATE OF CALIFORNIA
13 SS
COUNTY OF LOS ANGELES
14

15 I, ANGELA Z. PARADBLA, CSR NO. 9659, OFFICIAL REPORTER

16 OF THE SUPERIOR COURT OF THE STATE OF CALIFORNIA, FOR THE


17 COUNTY OF LOS ANGELES, DO HEREBY CERTIFY THAT THE FOREGOING
18 PAGES 1 THROUGH 14 COMPRISE A FULL, TRUE, AND CORRECT
19 TRANSCRIPT OF THE TESTIMONY AND PROCEEDINGS HELD ON APRIL 30,
20 2010 IN THE ABOVE-ENTITLED MATTER.

21

22 MAY 4, 2010

23

24

25

26

27 CSR NO. 9659


28 OFFICIAL REPORTER
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2 STATE OF CALIFORNIA, COLINTY Of LOS ANGELES

3 I declare that: I am employed inlhe county of Los Angeles. California. I am over the age or
eighteen years and not a party to the \....ithin cause: my business address is 2049 Century Park
4 Suite 3200, Los Angeles, California 90067-3206.
5 On May 25. 2010, I served the Inr~pt"n document, described as:

6 (pROPOSEDI ORDER

7 I!l by placing 0 the original a true copy thereof enclosed in sealed envelopes
addressed as follows:
8
SEE ATTACHED SERVICE LIST
9
o (By Fax) By transmitting a true and correct copy thereof via facsimile transmission
10 10

II (By Mail) I am "readily familiar" with the practice of collection and


processing correspondence for mailing. Under that practice. it would be deposited
12 with U.S. postal service on that same day \"'ilh postage thereon fully prepaid al Los
A California, in the ordinary course of business. I am aware that on motion
13 of arty served. service is presumed invalid if postal cancellation date or
postage meter date is more than one day after date of deposit for mailing in
14 amdavil.

15 0 (By Personal Service) By personally delivering such envelope to the addressee.

16 I!l By causing such envelope to be delivered by the office of the addressee by


OVERNIGIIT DELIVERY via Federal or by other similar overnight
17 delivery service.
18 (State) I declare under penalty ofpeljury under the laws of the Stale of California
that the above is true and correct.
19
o (Federal) I that J am employed in the office of a member of the bar of this
20 court at whose direction the service was made.
21 Executed on May 2010 at Los Angeles. California.

23
24
25
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27

~,,~ 5347/21051-006 Currenlf19t25853v1

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SERV1CE LIST
2 Raphael Metzger. BY FEDERAL EXPRESS
Metzger law Group
3 40 I E. Ocean Blvd .. Suite 800
Long Beach, CA 90802-4966
4
Barry Van Sickle, Esq. BY U.S. MAil
5 1079 Sunrise Avenue. Suite B-315
Roseville. CA 95661
6
Marc Marmaro, Esq. 8Y U.S. MAIL
7 JetTer, Mangels, Butler & Marmaro LLP
1900 Avenue of the Stars, Seventh Floor
8 Los Angeles. CA 90067-4308

9 Kendrick L. Moxon, BY U.S. MAIL


Moxon & Kobrin
10 3055 Wilshire Blvd .. Suite 900
Los Angeles, CA 900 I0
II

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