DeCrescenzo v Scientology Laura DeCrescenzo Declaration - Motion to Compel PC Folders (Feb 2013)
Transcript of 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
7/30/2019 DeCrescenzo v Scientology Laura DeCrescenzo Declaration - Motion to Compel PC Folders (Feb 2013)
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1 ' DECLARATION OF LAURA A . DiCÿN lÿCR jESCENZO Y
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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.
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W ORDERS OR, TERMINATING SANCTIONS
7/30/2019 DeCrescenzo v Scientology Laura DeCrescenzo Declaration - Motion to Compel PC Folders (Feb 2013)
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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
ORDERS OR TERMINATING SANCTIONS
7/30/2019 DeCrescenzo v Scientology Laura DeCrescenzo Declaration - Motion to Compel PC Folders (Feb 2013)
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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
ORDERS OR TERMINATING SANCTIONS