Electronically FILED by Superior Court of California, County of Los Angeles on 03/04/2020 05:09 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by W. Moore,Deputy Clerk

ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

1 JEFFREY K. RIFFER, State Bar No. 87016
jriffer@elkinskalt.com
2 10345 W. Olympic Blvd.
Los Angeles, California 90064
3 Telephone: 310.746.4400
Facsimile: 310.746.4499
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Attorneys for Defendant David Miscavige
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF LOS ANGELES, CENTRAL DISTRICT
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9
CHRISSIE CARNELL BIXLER; CASE No. 19STCV29458
10 CEDRIC BIXLER-ZAVALA; JANE
ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

Telephone: 310.746.4400 • Facsimile: 310.746.4499

DOE #1; MARIE BOBETTE RIALES; [Assigned for All Purposes to:
11 and JANE DOE #2, Hon. Steven J. Kleifield, Dept. 57]
12
Los Angeles, California 90064

Plaintiffs, SPECIALLY-APPEARING
10345 W. Olympic Blvd.

DEFENDANT DAVID MISCAVIGE’S

13 v. REPLY IN SUPPORT OF MOTION TO
QUASH SERVICE OF SUMMONS AND
14 CHURCH OF SCIENTOLOGY COMPLAINT AND TO STRIKE
INTERNATIONAL; RELIGIOUS PLAINTIFFS’ PROOF OF SERVICE AS
15 TECHNOLOGY CENTER; CHURCH FRAUDULENT
OF SCIENTOLOGY CELEBRITY
16 CENTRE INTERNATIONAL; DAVID Date: March 11, 2020
MISCAVIGE; DANIEL MASTERSON; Time: 8:30 a.m.
17 and DOES 1-25, Dept.: 57
18 Defendants. RESERVATION ID: 770700581282
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Action Filed: August 22, 2019
20 Trial Date: Not Set
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 TABLE OF CONTENTS
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Page
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I. INTRODUCTION .................................................................................................. 4
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II. HALL’S DECLARATIONS ARE FRAUDULENT................................................ 5
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III. PLAINTIFFS’ DECLARATION OF MAILING IS FALSE OR
5 FRAUDULENT ..................................................................................................... 8

6 IV. PLAINTIFFS’ ALLEGATIONS REGARDING MR. MISCAVIGE’S

OFFICE ADDRESS ARE BASELESS AND IRRELEVANT ............................... 8
7
V. PLAINTIFFS’ ALLEGATION THAT MR. MISCAVIGE REFUSED THE
8 NOTICE & ACKNOWLEDGMENT PROCEDURE IS FALSE AND
IRRELEVANT ..................................................................................................... 10
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VI. CONCLUSION .................................................................................................... 10
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ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

Telephone: 310.746.4400 • Facsimile: 310.746.4499

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Los Angeles, California 90064
10345 W. Olympic Blvd.

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 1 TABLE OF AUTHORITIES
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Page(s)
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State Cases
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City Breeze, LLC v. Shahi,
5 No. B259117, 2016 WL 6236422 (Cal. Ct. App. Oct. 25, 2016) ............................. 4, 7
6 Gilbert v. Sykes,

7 147 Cal. App. 4th 13 (2007) ........................................................................................ 4

8 Lebel v. Mai,
210 Cal. App. 4th 1154 (2012) .................................................................................... 5
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Federal Statutes
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ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

Telephone: 310.746.4400 • Facsimile: 310.746.4499

Code of Civil Procedure § 128.7(b) ................................................................................... 7

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12 Code of Civil Procedure § 415.20(b) ................................................................................. 8

Los Angeles, California 90064
10345 W. Olympic Blvd.

13 State Statutes

14 Bus. & Prof. Code § 6068(d) ............................................................................................. 7

15 Rules

16 California Rules of Professional Conduct, Rule 3.3(a).................................................... 7

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California Rules of Professional Conduct, Rule 8.4(c) .................................................... 7
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 I. INTRODUCTION
1

2 Plaintiffs’ Opposition to Mr. Miscavige’s Motion to Quash (“Opposition” or

3 “Opp.”) “doubles down” in defense of Robert Hall, a process server who a Los Angeles

4 Superior Court Judge (Hon. William F. Fahey) has already found to be “evasive and

5 not credible.” Plaintiffs ignore the incontrovertible evidence (video footage)

6 establishing that Hall was not at the location on the dates and times he swore he

7 attempted to serve Mr. Miscavige. Hall filed a fraudulent Proof of Service and, rather

8 than acknowledging that undeniable fact and withdrawing the false declaration,
9 Plaintiffs instead attempt to reassert service was valid.

10 To that end, Plaintiffs offer nothing but the conclusory declaration of the
ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

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11 “evasive and not credible” Hall, which should be disregarded. See Gilbert v. Sykes,

12 147 Cal. App. 4th 13, 26 (2007) (“declarations that … are … conclusory are to be
Los Angeles, California 90064
10345 W. Olympic Blvd.

13 disregarded.”) See also Request for Judicial Notice submitted in support of Motion to

14 Quash, Ex. C (City Breeze, LLC v. Shahi, No. B259117, 2016 WL 6236422, at *2-3

15 (Cal. Ct. App. Oct. 25, 2016) (affirming order setting aside default judgment based on

16 Hall’s fraudulent Proof of Service and finding Hall’s testimony to be “evasive and

17 not credible”).

18 Plaintiffs attempt to characterize the Motion to Quash as a “he-said/she-said

19 debate,” Opp. at 2, between Hall’s declaration on one hand, and the declarations of

20 Warren McShane, Lewis Miranda, and Lynn R. Farny on the other. Plaintiffs ignore

21 the additional evidence before the Court: Images collected from digital archive video

22 recordings of the dates, time and location of the purported attempts at service,

23 conclusively establishing that Hall’s declaration of purported service is fraudulent.

24 Mr. Miscavige’s counsel made the same offer to Plaintiffs that CSI offered: to

25 make the digital archive footage for each of the dates in question available to

26 Plaintiffs’ counsel upon request, subject to an appropriate protective order. See

27 Motion to Quash at 9 n.3. Plaintiffs never requested to view the archive footage.

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 1 They know the video footage establishes Hall never attempted to serve Mr. Miscavige

2 as claimed; they know Hall’s declaration of service is fraudulent.

3 Perhaps recognizing the weakness of their position, Plaintiffs spend the

4 majority of their Opposition ascribing arguments to the moving papers that were

5 never in there.

6 Specifically, Plaintiffs argue that the purported service location has two

7 addresses and that Religious Technology Center has an office at one of those

8 addresses. See Opp. at 4, 6. But, this has nothing to do with the pending motion.
9 The moving papers do not discuss the address of the purported service
10 attempts, nor does the motion make any representations regarding the location of
ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

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11 Mr. Miscavige’s office. See Mr. Miscavige’s Motion to Quash (“Motion to Quash”).

12 Mr. Miscavige’s Motion to Quash simply explains that service was improper
Los Angeles, California 90064
10345 W. Olympic Blvd.

13 because (1) Hall never attempted service of Mr. Miscavige at the address Hall

14 claimed in his declaration of service, and (2) Mr. Pink never mailed the required

15 service copies following Hall’s purported substitute service. See Motion to Quash.

16 Thus, Plaintiffs’ arguments regarding the location of the purported service are
17 not relevant to the key issue before the Court: Whether Hall properly served Mr.

18 Miscavige through substitute service.

19 This Court should: (a) grant the Motion to Quash and (b) strike Hall’s

20 fraudulent declaration of service from the record. It should do so to protect the

21 integrity of the Court and to make clear to Plaintiffs, their counsel and Hall, that

22 such wrongful conduct has no place in this Court.

23
II. HALL’S DECLARATIONS ARE FRAUDULENT
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25 Plaintiffs do not deny that there can be no proper substitute service if the

26 process server did not first physically attempt service. Lebel v. Mai, 210 Cal. App.

27 4th 1154, 1164 (2012) (“Substituted service is valid only if a good faith, reasonable

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 1 effort at personal service … is first attempted.”).

2 Nor do they dispute that the Church of Scientology International (“CSI”),

3 which has offices located at 6331 Hollywood Boulevard, maintains stationary digital

4 video cameras positioned above the entrance to the lobby and in the alcove at the

5 outside of the entrance door that captures video images of all persons entering and

6 leaving the building 24 hours per day. Declaration of Lewis Miranda (“Miranda

7 Decl.”) ¶ 6; see also Declaration of Lynn R. Farny (“Farny Decl.”) ¶ 3. Likewise, they

8 do not deny that CSI has, in its possession, the digital video archive of the security
9 camera footage for October 7, 10, 15, and 17, 2019 (the days in question), from

10 midnight to midnight on each day. Farny Decl. ¶ 5.

ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

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11 Instead, Plaintiffs assert only that the “screen shots of surveillance videos do
12 not demonstrate the proofs of service, declarations of mailing or declarations of due
Los Angeles, California 90064
10345 W. Olympic Blvd.

13 diligence are false or fraudulent.” Opp. at 6. Plaintiffs’ bare-bones denial is

14 unsupported and nonsensical: The surveillance videos conclusively establish that

15 Hall did not enter the address where he claimed to have attempted service on any of

16 the dates and times that he swore in his declaration.

17 Specifically, the moving papers included a declaration from Lynn R. Farny

18 stating that no one attempting to serve legal papers appeared on the video footage at

19 any time on October 7, 15, or 17, 2019. Farny Decl. ¶ 7. Moreover, attached to Mr.

20 Farny’s declaration are screenshots of the security camera footage showing that

21 footage at approximately 30-second intervals for the five minutes before and the five

22 minutes after Hall declared, under penalty of perjury, that he attempted service at

23 6331 Hollywood Boulevard. See Farny Decl. ¶ 6 & Ex. A. No one attempting to serve

24 legal papers appeared in those screenshots. See id.

25 Someone attempting to serve legal papers on another Defendant did appear in

26 screenshots taken at 11:43 a.m. on October 10, 2019. See Farny Decl. ¶ 8 & Ex. B. 1

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1 Notably, if Mr. Farny were lying about the contents of the security camera footage,
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 1 But no one seeking to serve legal papers on Mr. Miscavige appeared at 6331

2 Hollywood Blvd. on October 10, 2019, at any time. See Miranda Decl., ¶¶ 7-10; Farny

3 Decl. ¶¶ 6-7.

4 To the extent Plaintiffs challenge the credibility, or completeness, of these

5 screenshots and supporting declarations, see Opp. at 6, their challenge is hollow. Mr.

6 Miscavige’s counsel offered to make the entire digital archive for each of the days in

7 question available to Plaintiffs’ counsel (and the Court). See Motion to Quash at 9

8 n.3.
9 This is at least the second time that Hall has filed a fraudulent declaration of
10 service. See Request for Judicial Notice submitted in support of Motion to Quash, Ex.
ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

Telephone: 310.746.4400 • Facsimile: 310.746.4499

11 C (City Breeze, LLC v. Shahi, No. B259117, 2016 WL 6236422, at *2-3 (Cal. Ct. App.

12 Oct. 25, 2016) (affirming order setting aside default judgment due to Hall’s
Los Angeles, California 90064
10345 W. Olympic Blvd.

13 fraudulent Proof of Service, finding Hall’s testimony to be “evasive and

14 not credible”)). 2

15 Plaintiffs ratify Hall’s fraud by submitting a second Hall declaration in their

16 Opposition, repeating the same, provably false statements regarding Hall’s alleged

17 service attempts, without making a good-faith investigation into the truth of those

18 statements by (at minimum) reviewing the security footage offered to them. See

19 California Rules of Professional Conduct, Rule 3.3(a) (“A lawyer shall not offer

20 evidence that the lawyer knows to be false.”); id., Rule 8.4(c) (“It is professional

21 misconduct for a lawyer to: … engage in conduct involving … reckless or intentional

22 misrepresentation”); Bus. & Prof. Code § 6068(d) (“It is the duty of an attorney …

23 never to seek to mislead the judge … by … a false statement.”); Code of Civil

24 Procedure § 128.7(b) (“By presenting to the court, whether by signing, filing,

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as Plaintiffs imply, he would have no incentive to admit that someone seeking to
26 serve legal papers appeared on the footage at 11:43 a.m. on October 10, 2019.

27 Neither Plaintiffs nor Hall dispute that the City Breeze trial court found Hall’s
2

testimony to be “evasive and not credible.” Their failure to address this finding
28 speaks volumes.
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 1 submitting, or later advocating, a pleading, petition, written notice of motion, or

2 other similar paper, an attorney . . . is certifying that to the best of the person’s

3 knowledge, information, and belief, formed after an inquiry reasonable under the

4 circumstances, . . . the allegations and other factual contentions have evidentiary

5 support . . . .”).

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III. PLAINTIFFS’ DECLARATION OF MAILING IS FALSE OR FRAUDULENT
7

8 Plaintiffs offer no explanation for the “disappearance” of the purportedly-

9 mailed service copies. Nor do they submit any evidence that the service copies were

10 actually mailed to Mr. Miscavige, beyond Mr. Pink’s original declaration. (Mr. Pink
ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

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11 provided no declaration in the Opposition.) Instead, Plaintiffs make the

12 unremarkable argument that Pink’s declaration, stating that he mailed the

Los Angeles, California 90064
10345 W. Olympic Blvd.

13 documents, should be credited simply because it was “signed under penalty of

14 perjury.” Opp. at 5-6.

15 Mr. McShane’s declaration — stating that the documents were never received
16 — was also executed under penalty of perjury. See Declaration of Warren McShane.

17 Moreover, the fact that the documents were never received, when considered in light

18 of all of the other evidence submitted with the moving papers, creates a reasonable

19 inference that the documents were never mailed. Despite having the opportunity to

20 provide additional evidence of mailing in support of the Opposition, Plaintiffs do not

21 (or cannot) do so. Thus, Plaintiffs have not carried their burden to establish

22 compliance with the mailing requirements of Code of Civil Procedure § 415.20(b).

23 IV. PLAINTIFFS’ ALLEGATIONS REGARDING MR. MISCAVIGE’S OFFICE

ADDRESS ARE BASELESS AND IRRELEVANT
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25 Unable to defend Hall’s fraudulent Proof of Service, Plaintiffs spill

26 considerable ink attempting to reshape the record and issues before the Court.

27 Plaintiffs assert that (a) 6331 Hollywood Boulevard and 1710 Ivar Avenue are

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 1 separate entrances to the same building and (b) Mr. Miscavige has an office in that

2 building, such that he may be served there. Id. at 4, 6; Declaration of Valerie

3 Haney. 3

4 This has nothing to do with Mr. Miscavige’s Motion to Quash. Mr. Miscavige

5 did not challenge the purported substitute service based on the location of the alleged

6 attempts at service. See generally Motion to Quash.

7 Hall’s declaration of service was fraudulent because Hall never attempted to

8 serve Mr. Miscavige at the time and place that Hall claims he attempted service, or
9 anywhere else for that matter. See Motion to Quash at 7-10.

10 Hall claimed in his initial Declaration of Proof of Service and in his declaration
ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

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11 attached to the Opposition papers that he served Mr. Miscavige at 6331 Hollywood

12 Boulevard. But, video footage shows that he never appeared at that address on the
Los Angeles, California 90064
10345 W. Olympic Blvd.

13 dates and times he claimed.

14 Accordingly, Hall did not (1) make sufficient attempts to serve Mr. Miscavige
15 personally at 6331 Hollywood Boulevard (or anywhere else), or (2) properly serve Mr.

16 Miscavige via substitute service as claimed.

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3 Plaintiffs’ purported evidence that Mr. Miscavige’s office address is at 6331
Hollywood Boulevard is meaningless. The picture provided was copyrighted in 1993
22 – over 25 years ago and establishes nothing about the current location of Mr.
Miscavige’s office. There are countless pictures of Mr. Miscavige in offices around the
23 globe, e.g. at www.davidmiscavige.org. The assertion in Valerie Haney’s declaration
24 is also stale. She asserted in her own lawsuit (which has been ordered to religious
arbitration) that she was removed from her position in 2005. See First Amended
25 Complaint, Haney v. Church of Scientology International, et al., California Superior
Court, County of Los Angeles, Case No. 19STCV21210, ¶ 56. Her First Amended
26 Complaint was written by the same attorneys who filed Plaintiffs’ Opposition. They
27 knew, when they filed the Haney declaration with this Court, that the information in
that declaration was 15 years out of date. Moreover, Mr. Miscavige’s moving papers
28 did not dispute the location of a Religious Technology Center office.
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 V. PLAINTIFFS’ ALLEGATION THAT MR. MISCAVIGE REFUSED THE
1 NOTICE & ACKNOWLEDGMENT PROCEDURE IS FALSE AND
IRRELEVANT
2

3 Plaintiffs claim that this dispute is “unnecessary” because Plaintiffs agreed to

4 withdraw the challenged Proof of Service if Mr. Miscavige would sign a Notice and

5 Acknowledgment of Receipt, but that Mr. Miscavige refused.

6 The communications between the parties’ attorneys regarding this issue are in

7 writing. Those writings are before the Court. The writings demonstrate that

8 Plaintiffs’ assertions are false.

9 Mr. Miscavige’s counsel offered, on December 19, 2019, to sign the Notice and
10 Acknowledgment of Receipt when Plaintiffs withdrew the fraudulent Proof of Service.
ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

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11 See Plaintiffs’ Opposition, attaching Declaration of Robert W. Thompson, Ex. B (Mr.

12 Miscavige’s counsel’s December 19, 2019 letter: “When you withdraw the fraudulent
Los Angeles, California 90064
10345 W. Olympic Blvd.

13 Proofs of Service for Mr. Miscavige, we will sign the Notices.”). Plaintiffs refused.

14 Instead, Plaintiffs’ counsel demanded that Mr. Miscavige (a) withdraw his
15 Motion to Quash and (b) sign stipulations to be filed with the Court. See id., Ex. A.

16 Counsel for Mr. Miscavige attempted to negotiate agreeable language. Plaintiffs

17 refused to negotiate.

18
VI. CONCLUSION
19

20 Mr. Miscavige respectfully requests that the Court grant this Motion to Quash

21 and strike the Plaintiffs’ Proof of Service as a fraud on the Court.

22
DATED: March 4, 2020 ELKINS KALT WEINTRAUB REUBEN
23
GARTSIDE LLP
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25 By:
JEFFREY K. RIFFER
26
Attorneys for Defendant David Miscavige
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 PROOF OF SERVICE
1
Bixler, et al. v. Church of Scientology, et al.
2 Case No. 19STCV29458
3 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

4 At the time of service, I was over 18 years of age and not a party to this action.
I am employed in the County of Los Angeles, State of California. My business
5 address is 10345 W. Olympic Blvd., Los Angeles, CA 90064.

6 On March 4, 2020, I served true copies of the following document(s) described

as SPECIALLY-APPEARING DEFENDANT DAVID MISCAVIGE’S REPLY IN
7 SUPPORT OF MOTION TO QUASH SERVICE OF SUMMONS AND COMPLAINT
AND TO STRIKE PLAINTIFFS’ PROOF OF SERVICE AS FRAUDULENT on the
8 interested parties in this action as follows:
9 SEE ATTACHED SERVICE LIST
10
ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

BY FEDEX: I enclosed said document(s) in an envelope or package provided

Telephone: 310.746.4400 • Facsimile: 310.746.4499

by FedEx and addressed to the persons at the addresses listed in the Service List. I
11 placed the envelope or package for collection and overnight delivery at an office or a
regularly utilized drop box of FedEx or delivered such document(s) to a courier or
12 driver authorized by FedEx to receive documents.
Los Angeles, California 90064
10345 W. Olympic Blvd.

13 I declare under penalty of perjury under the laws of the State of California
that the foregoing is true and correct.
14
Executed on March 4, 2020, at Los Angeles, California.
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18 Averi J. Aburto

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 SERVICE LIST
1 Bixler, et al. v. Church of Scientology, et al.
Case No. 19STCV29458
2
Robert W. Thompson, Esq. Graham E. Berry, Esq.
3 Casey A. Gee, Esq. Law Office of Graham E. Berry
THOMPSON LAW OFFICES, P.C. 3384 McLaughlin Avenue
4 700 Airport Boulevard, Suite 160 Los Angeles, CA 90066-2005
Burlingame, CA 94010 Tel: (310) 745-3771
5 Tel: (650) 513-6111 Attorneys for Plaintiffs
Fax: (650) 513-6071
6 Attorneys for Plaintiffs

7 Brian D. Kent, Esq. William H. Forman, Esq.

Gaetano D’Andrea, Esq. David C. Scheper, Esq.
8 M. Stewart Ryan, Esq. Margaret E. Dayton, Esq.
LAFFEY, BUCCI & KENT, LLP SCHEPER KIM & HARRIS LLP
9 1435 Walnut Street, Suite 700 800 West Sixth Street, 18th Floor
Philadelphia, PA 19102 Los Angeles, CA 90017
10 Tel: (215) 399-9255
ELKINS KALT WEINTRAUB REUBEN GARTSIDE LLP

Tel: (213) 613-4655

Telephone: 310.746.4400 • Facsimile: 310.746.4499

Fax: (215) 241-8700 Fax: (213) 613-4656

11 Attorneys for Plaintiffs Attorneys for Defendant David Miscavige
12 Jeffrey P. Fritz, Esq.
Los Angeles, California 90064

Robert E. Mangels, Esq.

10345 W. Olympic Blvd.

SOLOFF & ZERVANOS, P.C. Matthew D. Hinks, Esq.

13 1525 Locust Street, 8th Floor Iman G. Wilson, Esq.
Philadelphia, PA 19102 JEFFER MANGLES BUTLER &
14 Tel: (215) 732-2260 MITHCELL LLP
Fax: (215) 732-2289 1900 Avenue of the Stars, 7th Floor
15 Attorneys for Plaintiffs Los Angeles, CA 90067
Tel: (310) 203-8080
16 Fax: (310) 203-0567
Attorneys for Defendant Religious
17 Technology Center
18 Marci Hamilton, Esq.
University of Pennsylvania
19 Fox-Fels Building
3814 Walnut Street
20 Philadelphia, PA 19104
Tel: (215) 353-8984
21 Fax: (215) 493-1094
Attorneys for Plaintiffs
22
Ricardo M. Martinez-Cid
23 Lea P. Bucciero, Esq.
PODHURST ORSECK, P.A.
24 One S.E. 3rd Avenue, Suite 2300
Miami, FL 33131
25 Tel: (305) 358-2800
Fax: (305) 358-2382
26 Attorneys for Plaintiffs

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