1. I have personal knowledge of all facts contained within this declaration and if called to testify thereto, I could and would be competently able to do so.

2. I am a party to the within litigation. Initially, when this lawsuit was filed against me by the Church of Scientology of California, I was unable to locate an attorney and therefore, my initial response to the case was in pro per.

3. I have been involved in continuous litigation with Church of Scientology entities since at least 1980. Initially, I sued the Church of Scientology of California in a Los Angeles County Superior Court action. That action went to trial in 1980 and I received a unanimous jury verdict in my favor in the amount of $30,000,000. Later, that verdict was reduced on appeal to $2.5 million but otherwise it has withstood every attack that Scientology has thrown at it. That action has come to be known as the "Wollersheim I" suit.

4. During the course of the Wollersheim I suit, I was sued not once, but twice by Scientology in federal court for the Central District of California. The first suit (Wollersheim II) was a RICO (Racketeer Influence Corrupt Organization) suit against myself, my attorneys and my expert witnesses which was filed by Religious Technology Center ("RTC") and Church of Scientology International ("CSI"). At the time of dismissal, the Court stated that the suit "borders on the frivolous and malicious."

5. The other suit filed in federal court during the course of the trial was a "civil rights action" filed by the Church of Scientology and various "Reverends" of other Scientology entities. This suit was also dismissed.

6. The fourth suit (Wollersheim IV) is this action. A defunct corporation, CSC sued me in an effort to engage me in prolonged litigation and to deprive me of my underlying judgment in Wollersheim I. The Court of Appeal stated at page 649 of its opinion in this matter, "When a litigant continuously and unsuccessfully uses the litigation process in filing unmeritorious motions, appeals and lawsuits, such actions have constitutional implications which may be reviewed on a motion under 425.16." Church of Scientology v. Wollersheim, 42 Cal.App.4th 628, 649.

7. A similar opinion was expressed in the unpublished Ninth Circuit Court of Appeal opinion in Wollersheim II. This opinion, issued April 11, 1996, states that Scientology has "utilized every device that we on the District Court have ever heard of to avoid such compliance, and some that are new to us. This non-compliance has consisted of evasions, misrepresentations, broken promises and lies, but ultimately with refusal. As part of this scheme to not comply, the plaintiffs have undertaken a massive campaign of filing every conceivable motion (and some inconceivable) to disguise the true issue in these pre-trial proceedings. Apparently viewing litigation as a war, plaintiffs by this tactic have had the effect of massively increasing the cost to the other parties, and, for awhile, to the Court. . . ." RTC v. Scott/RTC v. Wollersheim D.C. Nos. 9455781/9455920 - unpublished memorandum of opinion in an appeal from the United States District Court for the Central District of California.

8. RTC and CSI have once again sued me, this time in District Court in Colorado (Wollersheim V). This action is currently pending and is in the discovery stage.

9. On March 8, 1997, I traveled to Clearwater, Florida to participate in a demonstration at Scientology headquarters there. I was picketing regarding the suspicious death of a Scientology member, Lisa McPherson, who died while in the custody of the Church. The Coroner's Office found that she died of dehydration with her body covered with insect bites. During the course of the demonstration, one of the attorneys for Scientology in the Wollersheim V case, Elliot Abelson (who identifies himself as Scientology's general counsel), approached me in the company of Michael Rinder, the head of Scientology Legal and Intelligence Division. Mr. Rinder is an employee of the Office of Special Affairs of the Church of Scientology International which is NOT a party to the Wollersheim V case. Mr. Abelson advised me that he hoped that I did not take all the litigation he was involved with against me personally, it was just a job. During the course of this conversation, I advised him that I was confident that I would be able to prevail once again in the Wollersheim V litigation. I further advised them that it was likely that they would lose many of their copyrights that they were suing over. At this point, both Mr. Abelson and Mr. Rinder smiled at me and Mr. Rinder said, "You don't have enough money to do that."

10. Based on my continuous litigation with Scientology, since 1980, including litigation with Scientology entities, CSI, RTC and CSC, it is extremely clear that Wollersheim II, III, IV and V were filed for no other purpose than to deprive of my ability to collect my judgment in Wollersheim I and to beat me into submission through the continuous gross misuse of the litigation process. This continues to this day by the admission of Mr. Rinder in the Wollersheim V case. Scientology continues to throw its massive assets at me to make an example of me to the world. Scientology and its various entities, CSC, RTC and CSI want the world to know that it is useless to depend on the civil litigation system as Scientology will NEVER pay "one thin dime" to Larry Wollersheim, or anyone else.

11. I know, from personal knowledge from my 16 years of litigation with Scientology, that there is absolutely no corporate integrity whatsoever to Scientology.

I declare, under penalty of perjury that the foregoing is true and correct.

Executed this day of , 1997, at Boulder, Colorado.


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