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.IWP\Cases\9527\SUM-JUDG\Declarations\2013-10--03 - Kimoto Decl.wpd
BLUMBERG LAW CORPORATION
JOHN P. BLUMBERG, ESQ. (SBN 70200)
SINDEE M. SMOLOWITZ, ESQ. (SBN 123237)
444 W. OCEAN BLVD., SUITE 1500
FILED
LONG BEACH, CA 90802
TELEPHONE: ( 562) 43 7-04 03
TELECOPIER: ( 562) 432-0107
METZGER LAW GROUP
A PROFESSIONAL LAW CORPORATION
RAPHAEL METZGER, ESQ. (SBN 116020)
KATHRYN SALDANA, ESQ. (SBN 251364)
401 E. OCEAN BLVD., SUITE 800
LONG BEACH, CA 90802-4966
TELEPHONE: (562) 437-4499
TELE.COPIER: (562) 436-1561
Attorneys for Plaintiff
LAURA ANN DECRESCENZO
LOS ANGELES SUPERIOR COURT
OCT 09 2013
4. RLAPKf Cltrit(

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
LAURA ANN DeCRESCENZO, aka
LAURA A. DIECKMAN,
Plaintiffs,
vs.
CHURCH OF SCIENTOLOGY
INTERNATIONAL, a corporate
entity, AND DOES 1 - 20,
Defendants.
CASE NO. BC411018
Assigned to the Honorable
Ronald M. Sohigian, Dept. 41
DECLARATION OF SHANNON KIMOTO
IN SUPPORT OF PLAINTIFF'S
OPPOSITION TO DEFENDANTS' JOINT
MOTION _FOR SUMMARY JUDGMENT ON
THE GROUND THAT THE STATUTES OF
LIMITATIONS BAR THE ACTION
DATE:
TIME:
DEPT:
October 23, 2013
8:30 a.m.
41
DECLARATION OF SHANNON KIMOTO IN SUPPORT OF PLAINTIFF'S OPPOSITION
TO DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND
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1
Declarations\2013-10-03 - Kimoto Decl.wpd
DECLARATION OF SHANNON KIMOTO
I, Shannon Kimoto, declare as follows:
1. My name is Shannon Kimoto, and I am over the age of 18.
2. I have personal knowledge of the matters set forth hereinafter and, if called as
a witness, I would competently testify thereto.
Purpose of Declaration
3. In this declaration, I set forth the things that I saw, heard, read, and observed the
Church of Scientology (CSI) do that made me believe I could not challenge or sue the Church of
Scientology.
Membership in Sea Organization
4. I joined the Church of Scientology's Sea Organization (Sea Org) in 1983 when
I was 21 years old. The Sea Org is an internal organization within Scientology that is responsible for
overseeing the delivery of Scientology throughout the world. I remained in the Sea Org until 2004,
when I was 42 years old.
5. For a portion of my time in the Sea Org, I was employed by Religious
Technology Center (RTC) at Scientology's International Base near Hemet, California. RTC is the
highest level in the Church of Scientology and it oversees the actions of all lower organizations within
the Church of Scientology.
Fear of Leaving the Sea Organization
6. Throughout my time in the Sea Org, I did not believe that I would be allowed
to leave and that ifl attempted to do so, I would be tracked down and persuasive and coercive means
would be used to get me to return to the Sea Org. These beliefs and fears were based on my personal
experiences and observations as detailed below.
7. Ori two separate occasions, I attempted to walk away from the Sea Org. Both
times, I was followed and prevented from leaving.
8. In 2000, I was working at Scientology's International Base near Hemet,
California. I decided that I no longer wanted to be in the Sea Org, packed a backpack, and began
1
DECLARATION OF SHANNON KIMOTO IN SUPPORT OF PLAINTIFF'S OPPOSITION
TO DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND
THAT THE STATUTES OF LIMITATIONS BAR THE ACTION
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.IWP\Cases\9527\SUM-JUDG\Oectarations\2013-10--03 Kimoto Decl.wpd
walking away from the International Base on foot. I was followed by a security officer on motorcycle.
Additionally, Marian Dendui, a woman who worked in the legal/public relations department for
Religious Technology Center, and Muriel Dufrense, the port captain, followed me. I was brought back
to the International Base and restricted from leaving the Base. I also was assigned full-time manual
labor, was sec checked extensively (meaning interrogated about the reasons that I attempted to leave),
and was accused of being a plant and working for the FBI or CIA. During this time, I had no money,
no access to a phone, no vehicle, and no identification because my passport was being held by security.
9. I again tried to leave the Sea Org after I was assigned to the Rehabilitation
Project Force (RPF) in Los Angeles, California. The RPF is punishment/rehab program for Sea Org
members. On this occasion, I escaped Scientology's facilities with another person, and took the
subway to the beach. I only had a few dollars, and by the time that we made it to the beach, we
observed that we were being followed by Scientology personnel. Given that I had no money, no
identification, no vehicle, and I was being followed, I gave up, called in, and agreed to return to
Scientology's facilities.
10. I also followed other members of the Sea Org who attempted to "blow"
(meaning leave without authorization). The Church of Scientology would issue "blow drills" to find
members of the Sea Org who left without permission. During "blow drills," we would hold a meeting
to assign different members tasks in tracking down a person who left. During one "blow drill," I was
assigned a car to go to Idlewild, California, to determine if the person who left was staying at any of
the hotels in this town while others checked other local towns, bus stations, airports, etc. On another
occasion, I went to the airport in Los Angeles and searched all of the terminals for the person who left.
I also observed members of the Sea Org monitor the credit card and bank account information of
individuals who left to give clue to their whereabouts, search the rooms of individuals who left, and
contact their family and friends to track them down.
11. Based on the foregoing, I believed that the Church of Scientology was powerful
and that it would go to any length to accomplish its goals. I also believed that I would not simply be
allowed to leave the Sea Org.
2
DECLARATION OF SHANNON KIMOTO IN SUPPORT OF PLAINTIFF'S OPPOSITION
TO DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND
THAT THE STATUTES OF LIMITATIONS BAR THE ACTION
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e\WP\Cases\9527\SUM-JUDG'Declarations\2013-10-03 Kimoto Decl.wpd
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES )
I am employed in the County of Los Angeles, State of California.
I am over the age of 18 years and am not a party to the within action. My
business address is 401 East Ocean Blvd., #800, Long Beach, CA 90802.
On October 9, 2013, I served the foregoing document, described
as: DECLARATION OF SHANNON KIMOTO IN SUPPORT OF PLAINTIFF'S OPPOSITION TO
DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND THAT THE
STATUTES OF LIMITATIONS BAR THE ACTION on the parties to this action as
follows:
{BY MAIL) I caused copies of such document, enclosed in
sealed envelopes, to be deposited in the mail at Long Beach, California
with postage thereon fully prepaid to the persons and addresses indicated
on the attached list. I am "readily familiar" with the firm's practice of
collecting and processing correspondence for mailing. It is deposited with
U.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 invalid
if the postal cancellation date or postage meter date is more than one day
after the date of deposit for mailing set forth in this affidavit.
{BY FACSIMILE) I served the foregoing document by faxing
true copies thereof from facsimile number (562) 436-1561, to the facsimile
numbers indicated on the attached list. Said document was transmitted by
facsimile transmission, which was reported complete and without error.
x {BY PERSONAL SERVICE) I caused to be delivered such
document by hand to the firms listed on the attached list where personal
service is indicated.
{BY E-MAIL) I delivered such document by electronic mail
to the firms listed on the attached list.
{BY OVERNIGHT MAIL) I caused such document to be delivered
to the firms indicated on the attached list by Express Mail or by another
express service carrier, by placing the document in an envelope designated
by the carrier and addressed as indicated on the attached list, with the
delivery fees provided for, and depositing same in a box or facility
regularly maintained by that carrier or by delivering same to an authorized
courier or driver authorized by the carrier to receive documents.
__x_ {STATE) I declare under penalty of perjury under the laws
of the State of California that the above is true and correct.
{FEDERAL) I declare that I am employed in the off ices of
a member of this court, at whose direction service was made.
Executed on 9, 2013, at Long Beach, California.
,------,._____ ______ "
f
Nina S. Vidal, Declarant
4
DECLARATION OF SHANNON KIMOTO IN SUPPORT OF PLAINTIFF'S OPPOSITION
TO DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND
THAT THE STATUTES OF LIMITATIONS BAR THE ACTION
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-\WP\Cases\9527\SUM-JUDGIDeclarations\2013-10-03 Kimoto Decl.wpd .
SERVICE LIST
(DeCrescenzo v. Church of Scientology, Case No. BC411018)
Bert H. Deixler, Esq.
Kendall Brill & Klieger LLP
10100 Santa Monica Blvd., Suite 1725
LOS Angeles, CA 90067
(Church of Scientology International)
Matthew D. Hinks, Esq.
-ooo-
7 Jeffer, Mangels, Butler & Mitchell
1900 Avenue of the Stars, 7th Floor
8 Los Angeles, CA 90067-4308
9
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28
(Religious Technology Center)
5
DECLARATION OF SHANNON KIMOTO IN SUPPORT OF PLAINTIFF'S OPPOSITION
TO DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND
THAT THE STATUTES OF LIMITATIONS BAR THE ACTION
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9
10
18
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-IWP\Cases\9527\SUM-JUDG'Declarations\2013-10-03 - Kimoto Decl.wpd
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF LOS ANGELES )
I am employed in the County of Los Angeles, State of California.
I am over the age of 18 years and am not a party to the within action. My
business address is 401 East Ocean Blvd., #800, Long Beach, CA 90802.
On October 9, 2013, I served the foregoing document, described
as: DECLARATION OF SHANNON KIMOTO IN SUPPORT OF PLAINTIFF'S OPPOSITION TO
DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND THAT THE
STATUTES OF LIMITATIONS BAR THE ACTION on the parties.to this action as
follows:
~ - X - (BY MAIL) I caused copies of such document, enclosed in
sealed envelopes, to be deposited in the mail at Long Beach, California
with postage thereon .fully prepaid to the persons and addresses indicated
on the attached list. I am "readily familiar" with the firm's practice of
collecting and processing correspondence for mailing. It is deposited with
U.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 invalid
if the postal cancellation date or postage meter date is more than one day
after the date of deposit for mailing set forth in this affidavit.
(BY FACSIMILE) I served the foregoing document by faxing
true copies thereof from facsimile number (562) 436-1561, to the facsimile
numbers indicated on the attached list. Said document was transmitted by
facsimile transmission, which was reported complete and without error.
(BY PERSONAL SERVICE) I caused to be delivered such
document by hand to the firms listed on the attached list where personal
service is indicated.
~ ~ (BY E-MAIL) I delivered such document by electronic mail
to the firms listed on the attached list.
~ - (BY OVERNIGHT MAIL) I caused such document to be delivered
to the firms indicated on the attached list by Express Mail or by another
express service carrier, by placing the document in an envelope designated
by the carrier and addressed as indicated on the attached list, with the
delivery fees provided for, and Q.epositing same in a box or facility
regularly maintained by that carrier or by delivering same to an authorized
courier or driver authorized by the carrier to receive documents.
___lL_ (STATE) I declare under penalty of perjury under the laws
of the State of California that the above is true and correct.
(FEDERAL) I declare that I am employed in the offices of
a member of this court, at whose direction service was made.
Executed on October 9, 2013, at Long Beach, California.
Nina S. Vidal, Declarant
6
DECLARATION OF SHANNON KIMOTO IN SUPPORT OF PLAINTIFF'S OPPOSITION
TO DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND
THAT THE STATUTES OF LIMITATIONS BAR THE ACTION
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.IWP\Casesl95271SUMJUDG\Declara1ions\2013-1o:-03 Kimoto Decl.wpd
SERVICE LIST
(DeCrescenzo v. Church of Scientology, Case No. BC411018)
Kendrick L. Moxon, Esq.
Moxon & Kobrin
3500 W. Olive Avenue, Suite 300
Burbank, CA 91505
(Church of Scientology International)
John P. Blumberg, Esq.
-ooo-
7 Blumberg Law Corporation
444 W. Ocean Blvd., Suite 1500
8 Long Beach, CA 90802
(Plaintiff)
9
18
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20
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22
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(Updated August 23, 2012 jlp)
7
DECLARATION OF SHANNON KIMOTO IN SUPPORT OF PLAINTIFF'S OPPOSITION
TO DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND
THAT THE STATUTES OF LIMITATIONS BAR THE ACTION