DeCrescenzo v Scientology Laura DeCrescenzo Declaration - Motion to Compel PC Folders (Feb 2013)

7/30/2019 DeCrescenzo v Scientology Laura DeCrescenzo Declaration - Motion to Compel PC Folders (Feb 2013)

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ises\9527\D!SC-MOTMNSP-OEM .MTC\2013-02-07 - Plaintiff Declaration.wpd

BLUMBERG LAW CORPORATION

JOHN P . BLUMBERG , ESQ . (SBN 70200 )

SINDEE M . SMOLOWITZ , ESQ . (SBN 123237 )

444 W . OCEAN BLVD . , SUITE 1500

LONG BEACH , CA 90802TELEPHONE : (562 ) 437-0403

TELECOPIER : (562 ) 432-0107

METZGER LAW GROUP "-°S Angeles Superior Coun

A PROFESSIONAL LAW CORPORATION

RAPHAEL METZGER , ESQ . (SBN 116020) p£0 Q8 2013KATHRYN SALDANA , ESQ . (SBN 251364 )

4 01 E . OCEAN BLVD. , SUITE 8 00 John A. Clarkey€xacutive Qfficer/r iprk

LONG BEACH , CA 90802-4966 By ._ Prnn?TELEPH ONE: (562) 437-4499 &flAUNiJvWESLEY "TELECOPIER : (562 ) 436-1561

Attorneys for PlaintiffLAURA ANN DECRESCENZO

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICTLAURA ANN DeCRESCENZO , aka

LAURA A . DIECKMAN,Plaintiffs,

vs.

CHURCH OF SCIENTOLOGY

INTERNATIONAL , a corporate

entity, AND DOES 1-20 ,

Defendants .

CASE NO . BC411018Assigned to the HonorableRonald M. Sohigian , Dept . 41

DECLARATION OF LAURA A.

DIECKMAN (DECRESCENZO) . INSUPPORT OF PLAINTIFF,S MOTIONTO COMPEL COMPLIANCE WITH THECOURT'S DISCOVERY ORDERS OR

TERMINATING SANCTIONS

DATE : March 6 , 2013

TIME : 1 :30 p.m .

DEPT : 41

[FILED CONCURRENTLY WITH

PLAINTIFF'S NOTICE OF MOTION

AND MOTION TO COMPEL;

MEMORANDUM OF POINTS AND

AUTHORITIES ; DECLARATION OF

KATHRYN SALDANA ; [PROPOSED]

ORDER]

DECLARATION OF LAURA A . DIECKMAN (DECRESCENZO) IN SUPPORT OF

PLAINTIFF'S MOTION TO COMPEL COMPLIANCE WITH THE COURT'S DISCOVER

ORDERS OR TERMINATING SANCTIONS



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NJ

1 ' DECLARATION OF LAURA A . DiCÿN lÿCR jESCENZO Y

2E

3 JO, LaiiraA . Dieckmari j declare as follows:

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5 1, My :hame i s Laura Ann ©ieQlgnari, and I am over the age of 18, Ify married

6 name was Laura Aim DeC>escei«9.

7 2. I am the plaintiff in this lawsuit;

8 3 ;; llcdess the context indicates othe w ise, I have personallknowiedge of the niatter

9 set forth ; hereinafter and , if .called as a witness, I would competently testiy thereto,

jO 4. Oa iariig ; cay aii H tÿent0l© igyÿ 11 was told and understood that anyone who was senior to ine in my particular organization in CS

12 (including in :the Sea Organization); would be perxlitted t0 ; review the contents of any Of :my "PC

13 Folders,'' Thisjncluded individuals who were not aud itors .and who had ho aud itihg training . Xneve

14 believed that the contents: of my "PC Folders" wou ld be kSpti confidential between 0nly me;and the

15 person .whp audited me oh a particular occasion. I also do not: know all of the. ind ividuals, that had

16 access to my "PC Folders,"

17 5. I have reviewed Exhibit "43" to CSFs Pivilege LQfev Jwhichieofisists ofa list o

18 approximately 259 ris inaes thatCSIelaims were my ministers or clergymen. I was ieyer audited by the

19 majority of individuals identified on this l ist. Additionally,;! dp iot even recognize some, pf thename

20 included oil this list. :Eor others, while Irecogniize the names of the individuals listed I te ow that I Was

21 never<audited by those individuals and ;never considered; them to be my mihisters i or clergyinen ,

22 I declare under penalty pf perjury utder the laws of the State ; of California that the

23; foregoing is :tue and con nect.

24 Executed February 7,2013, at Albuqueiigiiei New Mexico.

W'V

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m ,

W ORDERS OR, TERMINATING SANCTIONS



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F:\wWCases\9527\DISC-MOTMNSP-DEM.MTC\2013-02-07 - Plaintiff Dedaration .wpd

PROOF OF SERVICE

STATE OF CALIFORNIA , CO UNTY OF LOS ANGELES )

I am employed in the County of Los Angeles , State of CaliforniaI am over the age of 18 years and am not a party to the within action . M

business address is 444 W . Ocean Blvd. , Suite 1500 , Long Beach , CA 90802

On February 8 , 2 013 , I served the foregoing document , describeas: DECLARATION OF LAURA A . DIECKMAN (DECRESCENZO) IN SUPPORT O

PLAINTIFF'S MOTION TO COMPEL COMPLIANCE WITH THE COURT,S DISCOVER

ORDERS OR TERMINATING SANCTIONS on the parties to this action afollows :

_ (BY MAIL ) I caused copies of such document, enclosed i

sealed envelopes , to be deposited in the mail at Long Beach , Californi

with postage thereon fully prepaid to the persons and addresses indicate

on the attached list. I am "readily familiar" with the firm's practice ocollecting and processing correspondence for mailing . It is deposited witU.S. Postal Service on that same day in the ordinary course of business

I am aware that on motion of any party served , service is presumed invaliif the postal cancellation date or postage meter date is more than one da

after the date of deposit for mailing set forth in this affidavit .

X (BY PERSONAL SERVICE ) I caused to be delivered suc

document by hand to the firms listed on the attached list where personaservice is indicated .

_ (BY E-MAIL ) I delivered such document by electronic maito the firms listed on the attached list.

_ (BY OVERNIGHT MAIL ) I caused such document to be delivere

to the firms indicated on the attached list by Express Mail or by anothe

express service carrier , by placing the document in an envelope designateby the carrier and addressed as indicated on the attached list, with th

delivery fees provided for , and depositing same in a box or facilitregularly maintained by that carrier or by delivering same to an authorizecourier or driver authorized by the carrier to receive documents .

X (STATE) I declare under penalty of perjury under the lawo f the State o f California that the above is true and correct.

_ (FEDERAL ) I declare that I am employed in the offices oa member of this court, at whose direction service was made.

Executed on February 8 , 2013 , at Long Beach , California .

Sindee M . Smolowitz, Declarant

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DECLARATION OF LAURA A . DIECKMAN (DECRESCENZO) IN SUPPORT OFPLA INTIFF'S MOTION TO COMPEL COMPLIANCE WITH THE COURT'S DISCOVER




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F:\WP\Cases\9527\DISC-MOT\lNSP-DEM.MTC \2013-02-07 - Plaintif Declaration.wpd

SERVICE LIST

(DeCrescenzo v. Church of Scientology, Case No . BC411018 )

-oOo-

Bert H . Deixler , Esq .

Kendall Brill & Klieger LLP

10100 Santa Monica Blvd.; Suite 1725

Los Angeles, CA 90067

(Church of Scientology International)

Robert Mangels , Esq .

Matthew D . Hinks , Esq .

Jeffer , Mangels , Butler & Mitchell

1900 Avenue of the Stars , 7[f Floor

Los Angeles , CA 90067-4308

(Religious Technology Center )

(Updated August 23 , 2012 jlp )

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DECLARATION OF LAURA A . DIECKMAN (DECRESCENZO ) IN SUPPORT OF

PLAINTIFF'S MOTION TO COMPEL COMPLIANCE WITH THE COURT'S DISCOVER


Documents

DeCrescenzo v Scientology Laura DeCrescenzo Declaration - Motion to Compel PC Folders (Feb 2013)