All of them, those in power, and those who want the power, would pamper us, if we agreed to overlook their crookedness by wilfully restricting our activities.
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DECLARATION OF KENDRICK MOXON
1. Kendrick L. Moxon, hereby declare and state:
1. I make the following statements of my own personal knowledge, and if called to testify thereto, I could and would do so competently.
2. I was admitted to practice law in the District of Columbia in September 1984. In January of 1986, I moved to California and was admitted to the California Bar in June of 1987. Since that time I have represented various Churches of Scientology, including Church of Scientology international ("CSI"), Church of Scientology Western United States ("CSWUS") and Religious Technology Center.
3. Following my California admission, I formed a partnership called Bowles & Moxon, thereafter Moxon & Bartilson, and then in March of 1998, the partnership was renamed Moxon & Kobrin. I am a partner in the law firm of Maxon & Kobrin, practicing in Los Angeles, California.
4. My primary clients have always been churches of Scientology and in particular, Church of Scientology International. Because the defense of the religion, its churches and members is a central responsibility of CSI, I am particularly knowledgeable of attacks to the faith and litigation filed against Scientology churches and the religion's leaders. I have been counsel in over 150 lawsuits involving one or more Scientology churches. Most of the legal threats and litigation brought against the churches have been extortive in nature — that is, frivolous actions brought to harm the churches in an attempt to extort settlements. Indeed, the normal actions filed against the churches involved outrageous and false allegations intended to inflame courts and juries against the religion, and pander to prejudice. Legal actions brought by the churches were nearly always undertaken to vindicate and preserve a statutory, civil or constitutional right that had been infringed in some fashion.
5. I have also provided legal representation respecting physical threats and even terrorist type threats to the Churches, their members and their leaders, including bomb threats, death threats, firebomb threats, assassination threats and other threats of violence of assorted kinds.
6. On behalf of my clients, and in the exercise of my legal and ethical responsibilities, our firm has often hired private investigators. My purpose in retaining investigators was uniformly to protect the Churches and members by acquiring information for use in litigation or potential litigation or in protection of rights, to disprove false allegations made against the Churches, and to assess physical and other threats. The use of lawful investigators to learn the extent and nature of danger to the Churches has been vital to the safety, security and survival of the Churches, their members and their leaders. Every investigator we have hired is instructed to pursue only legal means of investigation and comply with state and local rules.
7. The investigators utilized by the churches were uniformly retained by my firm, briefed by my firm and paid by my firm, in coordination with church staff of CSI or CSWUS. Never once in the 25 years I have performed these functions have I spoken with David Miscavige, the Chairman of the Board of Religious Technology Center, regarding investigations or investigators, nor have I had any written communication with him on the use or purpose of investigations or private investigators, I have no reason to believe he has or had any involvement with these functions.
I declare under the penalties of perjury of the laws of California and the United States, that the foregoing is true and correct. Signed this 15th day of October, 2009.
Kendrick L. Moxon