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BLUMBERG LAW CORPORATION
JOHN P. BLUMBERG, ESQ. (SBN 70200)
SINDEE M. SMOLOWITZ, ESQ. (SBN 123237)
444 W. OCEAN BLVD., SUITE 1500
LONG BEACH, CA 90802
TELEPHONE : ( 5 6 2 ) 4 3 7 - 0 4 0 3
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
TELECOPIER: (562) 436-1561
Attorneys for Plaintiff
LAURA ANN DECRESCENZO
e\WP\Casesl95271SUM-JUDG\Oeclara1ions\2013-10-08, Robert Levine.wpd
FILED
LOS ANGEi.ES SUPERIOR COURT
OCT 09 2013

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 ROBERT V.
LEVINE, PH.D., 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 ROBERT V. LEVINE, PH.D., 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\SUMJUDG\Oeclarations\2013-1 ()-08, Robert Levine.wpd
DECLARATION OF ROBERT V. LEVINE, PH.D.
I, Robert V. Levine, Ph.D., declare as follows:
1. I am a Professor Emeritus of Psychology at California State University, Fresno.
2. I have personal knowledge of the following matters and, if called as a witness,
I would competently testify thereto.
MY QUALIFICATIONS
3. I have been a Professor of Psychology at California State University, Fresno
since 1973. I have also served as Associate Dean of the College of Science and Mathematics and two
terms as Chair of the Department of Psychology at the university. I have served Visiting
Professorships at Universidade Federal Fluminense in Niteroi, Brazil; Sapporo Medical University in
Japan; Stockholm University in Sweden; and, Durham University in the UK. I am a Fellow in the
American Psychological Association and the Western Psychological Association and outgoing
President of the Western Psychological Association. I have won awards for both my teaching and
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research; serve on international and international professional boards; published four books, 90+
articles in professional journals, numerous conference presentations and given many invited and
keynote lectures. (For details of these activities, see my attached Vita).
4. My most relevant qualifications for the current declaration: I have been
specializing in the psychology of persuasion and mind control since 1984. I have been teaching a
self-designed course on this topic for more than twenty years. I have published a book, peer-reviewed
research and invited chapters and book reviews in professional journals, and presented research on the
topic at professional conferences. My most relevant publications for the current task are:
--Levine, 2003, R. The Power of Persuasion: How We're Bought and Sold
(2003) (updated paperback version published 2006). Hoboken, NJ: John Wiley & Sons. This book has
been translated into seven languages. It includes material on the psychological manipulations that have
been used in common situations such as sales and advertising as well as the manipulations used in
extreme groups such as cults. It includes a chapter on Jonestown and analyses of other cults, including
1
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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the Moonies and Hare Krishnas. The book includes a very small description of one personal incident
involving Scientology some time ago. (For more details about this book, see my website:
www.boblevine.net).
--Levine, 2003, R. (2003a). Cults. In E. Hickey (Ed.), Encyclopedia of Murder
and Violent Crime. Thousand Oaks, Ca.: Sage., 106-111. This invited chapter was written as an
introduction to the social psychology of cults. It summarizes research concerning what constitutes a
cult, the type of individuals who join cults, the typical structure of cults and the social psychological
dynamics that exert such a powerful influence on cult members.
5. My other relevant publications on the topic include:
--Levine, 2003, R. (2007, Sept.-Oct.). The evil that men do: Review of "The
Lucifer Effect" by Philip Zimbardo. American Scientist, 95, 440-442.
--Levine, 2003, R., Fast, N., & Zimbardo, P. (2004). The power of persuasion:
A field exercise. Teaching of Psychology, 31, 136-138.
--Levine, 2003, R. (2004). Milgram's progress: Review of "The Man Who
Shocked the World" by Thomas Blass. American Scientist, 93, 368-70.
--Levine, 2003, R. (2001, February). Beware the illusion of vulnerability. Net
and Books, 1, 24-27.
MATERIAL THIS DECLARATION IS BASED UPON
6. My comments are based upon a review of the "Declaration of Laura Ann
Dieckman (Decrescenzu) in Support of Plaintiffs Opposition to Defendants' Joint Motion for Summary
Judgment on the Ground that the Statutes of Limitations Bar the Action" and the accompanying
exhibits.
MY OPINION
7. In this declaration, I will address the physical, social and psychological pressures
\
experienced by Laura De Crescenzo both during her residence in the Church of Scientology and during
the period subsequent to her leaving the Sea Org . I will try to describe and assess the degree to which
2
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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.P\Cases\9527\SUM-JUDG\Oeclarations\2013-H}-08, Robert Levine.wpd
these pressures affected her ability to think clearly and to exercise her own free will in making
decisions of significance during these periods of time.
8. The question I will address in this declaration is whether a normal person-which
I define in this case as an average person without clear psychological pathologies-should be held
personally responsible for her decisions given the physical, social and psychological environment
created by Scientology. Should we expect DeCrescenzo to make reasonable, independent decisions
under these conditions?
9. First, let me briefly address the over-used and misleading term "brainwashing."
Totalistic commitments, such as the case of DeCrescenzo, are often described as the result of
brainwashing. The term was originally coined by a journalist, David Hunter, to describe the apparently
robot-like conversions of American servicemen captured in the Korean War. Hunter detailed a
program of systematic torture that produced these effects. (Levine, R. The Power of Persuasion: How
We're Bought and Sold (2003). Hoboken, NJ: John Wiley & Sons.) The term brainwashing has taken
on a vivid, frightening meaning over the years, as evidenced in films like "The Manchurian Candidate."
It is assumed to be the result of physical torture, forced brain surgery, or other coercive terrors.
10. Mind control needn't be based on torture, however. As DeCrescenzo describes
in her declaration, the more significant pressures she experienced were less overtly ominous than those
we associate with1 brainwashing. The control exerted by Scientology was more psychologically
sophisticated and, because of this, less obvious to targets like her. Scientology exerted a persistent and
potent program of psychological and social manipulation that effectively controlled DeCrescenzo's
thinking, behavior, emotions, and decisions. These pressures, though more subtle than what we think
of as brainwashing, effectively controlled DeCrescenzo's sense of reality. As a result, DeCrescenzo
became incapable of objectively evaluating anything she was told or threatened with.
11. In this document, I offer my analysis of the physical, social and psychological
forces experienced by DeCrescenzo under Scientology that I believe significantly affected her ability
to make clear, independent decisions concerning her participation, resistance to leaving, to critically
evaluate what she was told; and, further, how Scientology continued to exert these controls over
DeCrescenzo even after she did leave. An overview of what is to follow:
3
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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A.

C.
Robert Levine.wpd
The context: Being raised under Scientology.
The establishment of unquestioned norms of reality.
The totality of behavior, information and thought control that
encompassed DeCrescenzo during her time in Scientology.
D. Learned helplessness.
E. Threats and punishments.
F. The cumulative effect.
G. Scientology's control over DeCrescenzo for more than four
years after her exit.
H. The tipping point.
I. Concluding comments.
The Context: the Impact of Growing up in Scientology
12. To begin with, DeCrescenzo knew virtually no other way of thinking other than
that presented by Scientology. She was raised in Scientology. She began volunteering at a Church of
Scientology organization 'in Orange County at age six or seven. She began working essentially
half-time at a Church of Scientology organization in Albuquerque at age nine. At eleven years old, she
was sent, with her parents' consent, to receive training from Scientology's Technical Training Corps
in Los Angeles where she describes having worked fourteen hour days. At age twelve, again with her
parents' consent, she joined the Sea Org as a full-time employee where she continued working for the
next thirteen years. DeCrescenzo reports in her Declaration: "At that time, I had a seventh grade
education, and I signed a billion year contract (meaning that I agreed to work for the Sea Org for a
billion years)." She went to Scientology schools for most of her childhood. She says in her declaration:
"I took my high school proficiency exam at age fifteen or sixteen, and received no further "schooling"
in non-Scientology subjects (e.g., literature, history, etc.) after passing this exam." Her upbringing was
inseparable from Scientology. Even when aspects of her experience may have appeared to her-and to
outsiders-to have links to the outside world, virtually all of her interactions, information and education
was, in fact, being shaped by Scientology.
4
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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-P\Cases\9527\SUM-JUDG\Declarations\2013-1 Q.08, Robert Levine.wpd
13. In the cases of most organizations, the most difficult step in recruitment is to
elicit an initial commitment, no matter how small. It might be a willingness to attend a lecture, or a
free dinner, or to accept a free book or a free flower, or even to just stop and listen to what the recruiter
has to say. (Levine, R. (2003a). Cults. In E. Hickey (Ed.), Encyclopedia of Murder and Violent Crime.
Thousand Oaks, CA.: Sage, 106-111.) This initial step is known in sales lingo as getting a
"foot-in-the-door." In many cases, especially in so-called "cold: calls" (when the recruiter contacts a
stranger who has not requested to be contacted) this first step is considered the most difficult in the
persuasion process. It is also often considered the most important step. (Cialdini, R. B. (2001). The
science of persuasion. Scientific American Mind, 284, 76-81.) It is often the watershed in the process
whereby the target's resistance to each succeeding step is lowered as the target's trust in the salesperson
increases. As a result, each subsequent request becomes less difficult to achieve than the one before,
even if those subsequent steps entail more serious commitments than the earlier ones. In the case of
DeCrescenzo, she was born into Scientology meaning the encapsulation process began with the initial
step already totally achieved.
14. Being raised in Scientology also meant that subsequent training and socialization
into the norms and beliefs-the entire mindset--of Scientol<?gy came at her from many directions. When
typically being recruited by an organization, the persuasion efforts come from executives and other
leaders in the organization. The recruit understands that the organization has a vested interest in what
they are hearing and, as a result, is able to critically evaluate what they are hearing with this in mind.
In the case ofDeCrescenzo, however, her socialization was, particularly at the beginning, coming from
her family and friends within Scientology.
15. Much of her socialization was likely not even directly taught. Rather, like most
of what a child comes to internalize as normal and correct behavior, it comes through observation of
models who she trusted and respected. This mode ofleaming does not require explicit teaching; it is
something a child is simply programmed to do.
16. Once the mindset becomes established, it feeds on itself. The child's dominant
motive is to gain the approval of powerful others around them, most notably his or her parents and this
involves learning to trust the people her parents trust. In DeCrescenzo's case, this trust was transferred
5
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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aP\Cases\9527\SUM-JUDG\Declarations\2013-10-08, Robert Levine.wpd
to her superiors in Los Angeles when her parents sent her there with their blessings. From this, the
"pyramid of trust" could be easily extrapolated by the Scientologists who had almost total control over
her life.
1 7. A child's vision of right, wrong and normalcy can only come from what that
child is exposed to. One is not capable of imagining contrary alternatives without being presented with
these alternatives. (Levine, 2003, ibid.) This is not to say a child will choose to remain in that mindset
as they grow older. As people mature, they typically choose to associate with many types of people
who and may open them to new values and beliefs. In DeCrescenzo's case, however, she became
increasingly enmeshed with the thinking of Scientology as time went on. It appears from the
documents, in fact, that she learned to. assume that any action even remotely critical of Scientology was
morally wrong and would lead to severe disciplinary action (see below).
18. The entire mindset of Scientology-its beliefs, values, habits, rules, and even its
loaded language--was virtually the only reality DeCrescenzo was exposed to and, certainly, the only
mindset Scientology allowed her to accept for the first 25 years of her life. DeCrescenzo had almost
no choice but to believe that Scientology was normalcy.
Normative Pressures
19. This "normalcy" creates a powerful foundation for the organization to exercise
control over its members, especially young members like DeCrescenzo. Social norms refer to a group's
rules for accepted and expected behavior. They describe what most other "normal" people one
identifies with .tend to do, i.e. what is normal. Norms affect us on two levels: They exert social
pressure and they offer information about what the majority believes to be appropriate and correct.
The social pressures are powered by peoples' fear of rejection. Even when a person disagrees with
what everyone else seems to be doing, they may be reluctant to express disagreement for fear of (a)
standing out from the crowd; and (b) being disapproved of by the crowd .. We understand implicitly
what constitutes appropriate social behavior and that when we misbehave there are social
consequences. There is ostracism or humiliation from other people that in tum leads to shame,
rejection and isolation. (Levine, 2003, ibid.).
6
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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-P\Cases\95271SUMJUDG\Declara1ionsl2013-10-0a: Robert Levine.wpd
20. Informational pressures derive their power from what psychologists call the
principle of "Social Proof': If everyone else sees it this way, I must be wrong. (Cialdini, ibid.).
DeCrescenzo, having been raised and isolated within Scientology,was enormously prone to this effect.
Scientology saw to it that she was rarely exposed to any other ways of thinking and, when she was, that
she understood that this was wrongful thinking that none of her peers supported'. In her experience,
it seemed that virtually everyone believed in Scientology and, thus, this must be right.
21. Social norms are extremely powerful. We often think of legal authorities--the
police, the courts, prisons--as the most formidable enforcers of our society's rules. Rules and laws,
however, simply threaten with formal penalties. They work through fear of external threats. Once the
enforcers are gone, the individual can escape. With social norms, however, the punishment persists
inside the transgressor. Shame and guilt are, in a sense, like having control agents living in your mind;
as a result, they are always present.
22. Social norms, rather than formal rules, guide most of our behavior. (E.g.,
Kahan, D. M. (2000). Gentle nudges vs. hard shoves: Solving the sticky norms problem. University
of Chicago Law Review, 67, 607-645.) In the case ofDeCrescenzo, these codes of behavior often
conflicted with those of the surrounding world. Because of her experience in Scientology, however,
it would have been extremely unlikely for DeCrescenzo to understand this. The beliefs that may have
been considered normal, correct behavior outside context were understood to be deviant from the
norm within the culture of Scientology. To not succumb to the norm was not only understood to create
problems for oneself, and her parents, but was understood to be both wrongful thinking and a socially
disapproved act.
23. It would be highly unlike for a person who underwent the conditions experienced
by DeCrescenzo to be capable of rising above these normative pressures. Acceptance of the normalcy
of Scientology's dictates was virtually predetermined.
Totalistic Control of Behaviors, Information and Thoughts
24.. This mindset left DeCrescenzo extremely vulnerable to manipulation by
Scientology and Scientology used this power to establish virtually totalistic control over her.
7
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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25. The documents offer extensive evidence that Scientology systematically
manipulated DeCrescenzo on three dimensions: behavior control, information control and thought
control. These three types of control, taken together with their emotional components, encompass what
is popularly referred to as totalistic mind control. (Hassan, Steven (2000). Releasing the Bonds.
Somerville, MA: Freedom of Mind Press.)
A. Behaviors and activities were tightly regimented and controlled. The
experiences reported by DeCrescenzo describe a high degree of control of her daily behavior, including
regulation of the type of activities she engaged in and, in turn, how she spent her time. Feeding this
control was the fact that she essentially grew up in the Church. When not working in the Church per
se, she was spending her time with family members (before leaving to work at the Sea Org) and/or
friends who mirrored the same reality. As a result, she had little with which to compare her
experiences, resulting in the assumption that the level of control exerted on her behavior was normal.
(Cialdini, ibid.). Examples of behavior control included:
--Scientology controlled where Dec;rescenzo lived and with whom she
associated with. Relationships with others were monitored and strictly controlled. This
was especially the case with her relationships with family members, as can be seen
throughout the attached exhibits.
--Behaviors were often micromangaged. She writes: "The Master at
Arms for the HCO (MAA) was responsible for removing any type of "distractions"
from the Sea Org. The MAA acted as the 'Scientology police officer,' meaning that he
or she would periodically inspect the Sea Org facilities throughout the day to make sure
staff in the Sea Org had not left without authorization and would listen in on phone
conversations to make that the content of these phone calls was acceptable to the
Church of Scientology."
--Long and tightly regimented work hours. Her hours became
increasingly long as time went on, leaving her little time outside work.
--Keeping members constantly busy, and exhausted, is a common
strategy used by cults to keep members from thinking too much about alternatives, or
8
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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.P\Cases\95271SUM-JUDG\Declara1ions\2013-10-08, Robert Levine.wpd
thinking at all. It leaves neither time nor energy for critical thinking. (Levine, 2003,
ibid.) This appears to be have been very much the case for DeCrescenzo. She provides
an example of this: "When I was twelve years old and for about my first year in the Sea
Org, I worked from 8:30 a.m. until 10:30 p.m. Monday through Sunday. These were my
set hours because I was a "minor," but there were numerous times that I worked beyond .
10:30 p.m. On Sunday mornings, I was required to clean my living quarters. My only
time not working was on Sunday mornings, but I was not allowed to leave Scientology
facilities unaccompanied during. this time period. After my first year, and until
approximately 2001, I worked from 8:30 a.m. to 12:30 a.m. Monday through Sunday.
I would return to my quarters each night on a bus between 12:30 a.m. and 1 :30 a.m. My
only time not working was on Sunday mornings, but I was not allowed to leave
Scientology facilities unaccompanied during this time period."
--Her behavior was even more tightly controlled when she was being
disciplined. For example, DeCrescenzo recounts: "In 2001, I was sent to the
Rehabilitation Project Force (RPF) which is punishment/rehab program for Sea Org
members. During this time, I worked from about 6 or 7 a.m. until 9:00 p.m. seven days
a week with 15 minute meal breaks. Most of my work during this time consisted of
heavy labor, such as working in the mill, cleaning hallways, and building walls. "Lights
out" usually was at 10:30 p.m., and there was a quartermaster who came down the
hallway to make sure each person was in their room. The quartermaster would turn out
the lights in each room, and then would sit in the hallway all night long to make sure
that no one left.
--Work demands had the added effect of controlling her sleep patterns.
Sleep deprivation is another common technique of control in cults. It weakens a
person's mental energy during the waking day and, as a result, serves to dissipate
resistance. In her declaration, DeCrescenzo recalls "regularly being deprived of sleep
during my time in the Sea Org in order to work longer hours than my already
demanding schedule. For instance, when I was fourteen years old, I recall
9
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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Robert Levine.wpd
required to work for 3 days straight without even being allowed to go home or take a
shower and change my clothes. When I was provided a short shower break after 3 days,
I was told to immediately return and I continued working for two more days without
any sleep."
In summary, there were rigid rules and regulations about what DeCrescenzo was and was not allowed
to do, with both implicit and clear threats about what would happen to her if she did not obey. This
extended to extremes that altered the course of her life. Most profoundly, Scientology decided the
matter of her future motlierhood--as DeCrescenzo painfully learned when she was forced to have an
abortion.
B. Second, information was tightly controlled. DeCrescenzo received
virtually all of her information through filter of Scientology. This information was both selective
and distorted. Any information contrary to the wishes of Scientology was either modified or withheld.
"Upon joining the Sea Org, the Church of Scientology controlled my communications with my parents
and family members. This control ... continued for the duration of my time in the Sea. Org.," she
reports in her declaration. Examples of this include:
--All incoming and outgoing mail was approved by the church. For
almost her entire time at the Sea Org., incoming mail was received already opened and
she was required to leave all outgoing mail open.
--Outside phone calls were generally made in the presence of someone
from Sea Org. and/or monitored by a member. She describes the limitations this created
when communicating with her parents, who were her only significant outside source
of information.
--Education, to what extent it was offered, was under the control of
Scientology. As already indicated, DeCrescenzo took her high school proficiency exam
"at age fifteen or sixteen and received no further schooling" in non-Scientology subjects
(e.g., literature, history, etc.) after passing this exam." She "never received any formal
schooling in traditional subjects such as math, science, or history during my time in the
Sea Org."
10
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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28 II
.P\Cases\9527\SUM-JUDG\Oeclarations\2013-10-08, Robert Levine.wpd
--Communication with outsiders was severely limited. In DeCrescenzo's
case, the restrictions on communicating with her parents were especially significant.
In the section on "Thought Control" (below) I describe some of the psychological
manipulations that were used to pressure her against making these visits.
--Even when DeCrescenzo was exposed to the outside world, she was
tightly supervised and understood the consequences of communication with sources
critical of Scientology. We see multiple examples of this in the attached exhibits. She
describes, for example, how after visits to her parents and grandparents visits, she was
required to report everything that occurred with particular reference to anything that
Scientology did not approve. Two examples: In Exhibit K she writes: "I recall being
asked if I had any "doubts" about being in the Sea Org over the course of that year
[1994]. I also was asked if had handled all problems with my mom raising concerns
about me being able to leave and visit her, whether my mom ever tried to pull me out
of the Sea Org, what my mom thought of the Sea Org, whether my mom had any Black
PR on the Sea Org (meaning whether she had any bad views of the Sea Org or bad
"public relations" related to the Sea Org), and whether my mom was actively involved
in the Church of Scientology. I was asked the same series of questions with respect to
my dad, grandparents, and other family members." In Exhibit L she writes: "I felt
compelled to report my mom to my seniors if she asked me questions about whether or
not I wanted to be in the Sea Org or raised concerns that I was not allowed to leave
when I requested time off." Needless to say, Scientology was able to control what
information was and what was not shared during these visits through these
interventions.
--She reports how these interactions were sometimes more directly
monitored. For example, "I also recall from my review of Exhibit "M" that I was
directed to call my grandfather in the presence of the MAA (see below) so that they
could observe my conversation and how I handled my grandfather."
11
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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a\Cases\9527\SUM-JUDG\Declarations\2013-10-08, Robert Levine.wpd
--Insiders were prohibited from contact with former members. This was
especially significant for two reasons. First, it cut members off from the people who
were especially likely to provide them with information and ideas that were challenged
Scientology. Second, it was understood that a person who disobeyed the edicts of
Scientology would be declared a suppressive person themselves. This meant that you,
too, would never again be able to have contact with anyone inside Scientology.
--It was well understood that, even if one had information challenging
Scientology, that there were severe consequences for verbalizing this information. It
would risk discipline for both oneself and the person one spoke to-who, in turn,
understood that they were obligated to report your behavior to the authorities. As a
result, even if a member possessed information that was not sanctioned by Scientology,
it was unlikely to be communicated to anyone else.
In summary, as a result of these and other controls, DeCrescenzo received almost all her input from
Scientology. She had virtually no access to outside information that would have enabled her to critical
evaluate what Scientology presented to be true and normal.
C. Thought control. The most important consequence of behavior and
information control is how they provide a platform for controlling an individual's thoughts. Scientology
then used a number of techniques to control DeCrescenzo's thoughts that are typical of manipulative
groups. They showed considerable sophistication in their applications of these techniques. A few
examples:
--DeCrescenzo was encouraged to think in simplistic black and white
terms. Scientology was good; all else was evil. The tenets of Scientology were "right"
and any challenges were "wrong." This simplistic thinking is a common lure in cults,
which often attract recruits by offering people simple answers to complex problems.
(Levine, 2003, 2003a, ibid.). Whether or not Scientology did offer solutions is beyond
the scope of my report. On the psychological level, however, it seems clear that this
way of thinking successfully created dependency on the group. Members were actively
encouraged to label anything outside of Scientology as bad. There were no grey zones
12
DECLARATION OF ROBERT V. LEVINE, PH.D., 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-JUDG\Declarations\2013-10-08, Robert Levine.wpd
when it came to matters of right and wrong. If one left Scientology it would mean
permanent separation from not only everything that one was familiar with but with the
group that stood for goodness. (Levine, 2003, 2003a, ibid.).
--As in many cults, members learned simplified, insider labels to
evaluate people's thoughts about anything related to the organization. For example,
DeCrescenzo describes feeling compelled to report anything even remotely negative
that her mother or family members might ever say about Scientology. She was asked
to report, for example, whether her mother had "asked me questions about whether or
not I wanted to be in the Sea Org or raised concerns that I was not allowed to leave
when I requested off." As might be expected of any concerned parent whose child
is living away from home, her mother often did ask questions like these. But when
pressed to report on her mother, DeCrescenzo was expected to use black and white
terms. For example, she quotes one such report she wrote to her seniors in which she
says her mother has "black PR on the SO" [meaning bad views of the Sea Org]. As
another example, she was to report anything a family member had said that was
"out-ethics" (meaning anything that is against the beliefs of Scientology). This type of
"loaded language" served the additional purpose of making one feel like an insider.
--This approach divided people into "us" vs. "them." Psychologists refer
to this as the "ingroup-outgroup bias" which, it has been well-demonstrated, leads to
both antagonism toward the out-group and cohesion within the in-group. In cults, this
cohesion often takes the form of further dependence on the ingroup and a fear,.
sometimes described by former cult members as a phobia, of separation from the group.
(Myers, David (2009). Social Psychology (10th ed.). New York: McGraw-Hill.)
-- Scientology told DeCrescenzo what to think. She was required to
'
obtain permission from the Church for any major decisions. If she resisted, she faced
punishments.
The pressures of thought control served to manipulate DeCrescenzo's sense of reality and,
consequently, to obstn.ict her ability to make independent decisions. Almost by definition, a person
13
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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a\Cases\9527\SUM-JUDG\Deciara1ions\2013-1Q..08, Robert Levine.wpd
who is under mind control finds it difficult or impossible to understand that they are under mind
control unless they have access to feedback from the outside. DeCrescenzo was both a victim of
control and was deprived of being able to recognize the extent to which she was being controlled.
26. In summary, there was virtually totalistic control over DeCrescenzo's behavior,
information and thoughts. Scientology encountered little resistance in administering this control as a
result of her being raised, and thus totally socialized, in the organization. In an organization that wants
to exert totalistic control over their membership, typically one of the watershed steps in achieving total
commitment from a member is to get them to move on to the group's "campus." They might be asked
to move to The Farm or The Church, perhaps explaining to the recruit that it would save the
organization money and increase efficiency. Problems often for the member when, coupled
with this move, they are required to cut off ties with outsiders. This is a difficult demand for most
organizations to achieve with a member. When successful, however, the organization gains a new
level of control over the member. In the case of DeCrescenzo, she was not only born into Scientology
but was sent to reside in the Sea Org, at the age of 12, with her parents' blessing. Everything about her
life-family, social, economic, education, information-unfolded in a physically and socially isolated
environment under the control of Scientology.
Learned Helplessness and Hopelessness
27. The concept of learned helplessness refers to the feeling of resignation and
hopelessness that results when a person repeatedly fails at attempts to alter the course of bad events.
The dynamic is well established in research studies, most notably through the work of Professor Martin
Seligman and his colleagues. These studies find that, when confronted by a painful event, humans and
animals will initially take active steps to stop the pain or remove herself from the pain but, after
repeated failures, most people will give up. The victim is then left with a chronic feeling of
hopelessness which is often accompanied by depression. They lose their initiative at this point and will
no longer try to help themselves, even if at some point they actually gain the power to do so; hence,
the term, "learned helplessness." (E.g., Seligman, M. ( 197 5). Helplessness: On Depression,
Development and Death. San Francisco: Freeman.)
14
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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-P\Cases\95271SUM-JUDG\Dfciarations\201J..1().()8, Robert Levine.wpd
28. When reviewing DeCrescenzo's declaration, one may ask why it took her so long
to leave a situation that made her so unhappy. Why would she not revolt? I have already reviewed
some of the forces that caused her to adopt Scientology's way of thinking so totally that she was unable
to critically evaluate her conditions and her options. Learned helplessness helps one understand the
emotional feelings that her conditions created. The research on learned helplessness has demonstrated
that, when a person is convinced that they lack control over their suffering, it is "normal" to fall into
a cycle of hopeless passivity, leading to depression, which leads to lack of motivation, which leads to
further hopelessness, etc. Research conducted on dogs has found that an animal caught in this cycle
may eventually become so passive that they cease eating and eventually die.
29. A suicide attempt is, by any psychiatric definition, a pathological behavior. In
this case, however, it was predictable. It is an example of perhaps the strongest finding in social
psychology, which has been shown over and again in empirical studies: The power of an oppressive
situation to cause otherwise psychologically healthy people to behave in unhealthy ways: Pathological
conditions, like those created by Scientology, create pathological behavior. (e.g. Zimbardo, Philip
(2007). The Lucifer Effect: Understanding How Good People Turn Evil. New York: Random House.)
The fact that DeCrescenzo's most aggressive action to leave Scientology was to attempt suicide is a
telling reflection of how hopeless she had come to perceive her available options. The fact that she
judged, apparently correctly, that Scientology offered this as one of the few options for escaping the
organization is even more telling about the organization. A healthy organization promotes
self-betterment; the successful employee is encouraged to move forward with their lives. Scientology
took the opposite approach. It was only when DeCrescenzo appeared to be so broken that she was a
liability to the organization that she was discarded.
Threats and Punishments
30. DeCrescenzo lived almost entirely within the mindset of Scientology from the
beginning of her life until the middle of 2008, more than four years after defecting from the Sea Org
(see below for further discussion). During that time, virtually everything she did and thought was
dictated by the rules, expectations and other demands of her Scientology superiors. The unifying theme
15
DECLARATION OF ROBERT V. LEVINE, PH.D., 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-JUDG\Declarations\2013-10.08, Robert Levine.wpd
of these demands appears to have been total and unquestioned commitment to the organization. The
rulemakers within Scientology appear, however, to have feared that followers like DeCrescenzo needed
to be further controlled if their aims were to succeed. They needed to use sticks as well as carrots.
These sticks were administered in a web of threats and punishments. A few examples:
-- DeCrescenzo was required to divulge information, sign documents and make
other commitments that led her to believe she was legally bound to Scientology. She understood that
these statements and signed documents would be kept on file and that they would be used against her
should she ever publicly challenge Scientology or try to leave.
--She was repeatedly required to report on herself. A notable example was the
extensive, detailed and often very personal "Life History" questionnaire she describes (see Exhibit
AA), which she completed about five times a year. It was understood that any "wrong" answers would
mean either further training or discipline. Most of the questions were ordinary. Some, however, would
certainly require some degree of lying in order to meet her examiner's expectations. For example:
-"Have you ever had doubts about being in Scientology and/or the Sea Org?":
-"Have any of your family or close friends expressed skepticism or been critical
of Scientology?"
If she answered yes to any of the questions, she was required to provide full details of her
transgressions.
31. Scientology must have certainly known that no person with even a mild level
of critical ability could honestly answer these questions with a definitive "No." Questions such as these
were all part of a larger pattern inquisition that encouraged, and often required, that DeCrescenzo
essentially, agree to her own punishment should she ever stray from Scientology. This was part of a
larger pattern requiring her to reveal unflattering information about herself that could be used against
them at any time.
-- DeCrescenzo was sometimes required to make untrue confessions of a more
serious nature. These confessions had multiple consequences. DeCrescenzo understood they could
be used to threaten her with future retributions. Scientology also used these threats to continue to
control her after she left.
16
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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-P\Cases\9527\SUM-JUDG\Declaralions\2013-10-08, Robert Levine.wpd
-- Members were manipulated to actively participate in this system of threats.
As a notable example, spying was encouraged. This enforced the strict control of what information
would be available to members. Members were encouraged to turn in anyone who deviated from
proscribed rules. As we see in her declaration, DeCrescenzo understood it was dangerous to speak to
others in any way critical of Scientology and it put the person you spoke to, who would be punished
if the authorities found out they did not report you, in a difficult position. It was even worse to speak
about extreme behaviors such as wanting to defect. This strategy of requiring members to inform on
one another is a powerful means of breaking down individual trust. (Levine, 2003, ibid.) It deters
members from coming together to fight perceived injustices. To borrow from the military term, it
represents an application of the truism to "divide and conquer." It also discourages anyone from sharing
any information that might have heard that is challenging to the group.
--These pressures were sometimes convoluted in ways that put DeCrescenzo in
impossible binds. On one occasion, for example, she reports that: "I was scared to say certain things
to my mom and afraid that I would upset her." Then, on another occasion, she writes: "I disclosed to
my auditor that my mom expressed upset about me not being able to visit my family and I that I
claimed all responsibility for her upset, even though I was equally confused and upset about not being
able to see my family when I requested to do so." On another occasion: "I explained [to an examiner]
my concerns that she would "cause a problem" if I could not take time off or could not take time off
when originally planned. I explained to her all of the reasons that I may not be able to leave and that
she should not expect me to be able to leave at any particular time. I also noted in this document that
I missed my mom. From reviewing this document, I recall that I did not want to upset my mom and that
I was scared about what would happen to me in the Sea Org if my mom did not stop."
--Another example of these complicated psychological pressures: In Exhibit Q,
DeCrescenzo describes a memo she wrote in which she reported "a number phone calls and pages that
I received on a beeper from my mom and the concerns that my mom expressed to me that I caused my
sister to be sick because I made statements to my sister about her decision not to join the Sea Org. I
previously had been ordered by Aaron Tweedell, the HCO Chief, to convince my sister to join the Sea
Org despite her decision not to do so. I believed'that if I did not try to convince.my sister to join, I
17
DECLARATION OF ROBERT V. LEVINE, PH.D., 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-JUDG\Oeclarations\2013-10-08, Robert Levine.wpd
would be considered to have "doubts" or bad feelings about the Sea Org and would be assigned lower
conditions and manual labor. Mr. Tweedell required me to talk to my sister and suggested that I would
be questioned about my feelings about the Sea Org ifl did not try to convince her to join."
--Even thinking bad thoughts about Scientology was a punishable offense.
Perhaps the most overtly Orwellian of Scientology's thought control manipulations was the auditing
process. In most cases auditing was presented to the member as an essential step in reaching their
highest religious potential, i.e. going "Clear." In some cases-what are described as situations where
the auditor would announce "I'm not auditing you"--wayward members would be told it was to correct
misdeeds or help improve their contributions to the organization. In both cases, however, these
supposed lie detectors were assumed by those being tested to be capable of revealing their true inner
thoughts. I will not address the well-researched limitations of lie detectors, even when administered
by trained experts. (Adelson, R. (2004). Detecting deception: The polygraph in doubt. APA Monitor,
35, p. 71.) What is important is that the members believed these In.achines could reveal their innermost .
thoughts. In Orwellian terms, these were the "thought police." Given the ubiquity of these tests and
the importance placed upon them, the auditing process became capable of pressuring members not only
to overtly agree with everything promoted by Scientology but to try to stop thinking about anything
negative.
--It would have been difficult, given her background and training for
DeCrescenzo not to believe threats would be acted upon. And, it appears, they usually were.
DeCrescenzo knew this from first-hand experience as the recipient of punishment (e.g., when she was
sent to the Rehabilitation Project in 2001, as described earlier). She also had first-hand experience in
the process of punishing others. For example, she reports: "for approximately 6 years during my time
in the Sea Org, I worked as the Investigations and Evaluations Director for the Commodore's
Messenger Organization International Extension Unit (CMO IXU). The CMO IXU was responsible
for keeping an eye on various management organizations, including the Sea Org. In this position, I
specifically reviewed other Sea Org members' files and their Life History Questionnaires to determine
what information we had available regarding these individuals. If they threatened to leave or acted out
against Scientology, we would then use information from their files to convince them to stay or to get
18
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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.P\Cases\9527\SUM-JUDG\Declarations\201 J.1()-08, Robert Levine.wpd
them to stop acting out." As a result, DeCrescenzo understood that any negative comments she herself
made on the Life History Questionnaires or elsewhere would be used against her.
--Finally, early on she learned first-hand what she would face if she ever brought
_a lawsuit against Scientology. She recalls: "At age seven, I first picketed a lawsuit filed against the
Church of Scientology outside a courthouse in Los Angeles. Seeing the Church of Scientology pull
together such a big group of people to picket this lawsuit and create such a commotion made clear to
me that the Church of Scientology was a formidable force and that it would go to every length to bring
down people who filed.lawsuits against it.
The Cumulative Effects
32. DeCrescenzo was exposed to many and frequent threats of punishment for
questioning or even remotely defying anything about Scientology. Some of these requirements seemed
so unbelievable-for example, agreeing to work for the Sea Org for one billion years or promising to
repay a $120,000 "freeloader bill" (described below) if she ever left--that it is tempting to question why
anyone would take Scientology's threats seriously. In fact, one should question why DeCrescenzo,
given her background in Scientology-being raised a Scientologist, educated and socialized within the
organization, been subject to virtually totalistic mind control, having been de-motivated by feelings
of helplessness and hopelessness-- would not believe anything the organization told her. She knew no
other reality.
33. A related question is why didn't she leave sooner. I believe DeCrescenzo sums
up the answer with impressive insight:
"There were a few times when I was able to get away from the Sea Org
without approval and without an escort. However, on each of these
occasions, I returned to the Sea Org because I had no money, no
experience, no car or driver's license, no understanding of the
non-Scientology world, and because Church of Scientology officials
told me that if I did not return, I would be subject to a Freeloader bill
(meaning a financial bill for all of the services that I received during my
time in the Sea Org). I also was told by HCO Chiefs, Security
Personnel, and the Supercargo that by leaving, I was hiding crimes or
bad acts that I had committed and that I would lose all contact with my
family and friends. I also observed during my time in the Commodore's
Messenger Organization International Extension Unit (CMO IXU) that
the Church of Scientology tracked down and followed anyone who left
19
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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a\Cases\9527\SUMJUDG\Oeciarations\2013-1().()8, Robert Levine.wpd
without permission; this was referred to as a "blow drill." This included
tracking activity on the person's bank accounts, going to airports to
search for the person, calling family members, and other similar
conduct. I was personally involved in "blow drills" during my time the
CMO IXU and recall providing Sea Org members' social security
numbers to a Private Investigator who would then track the person
down. I also personally reviewed the files of Sea Org members who left,
and instructed others on how to use information from their files to track
them down and get them to return. As a result, I believed that even if I
tried to leave permanently, I would be tracked down and returned to the
Sea Org."
Scientology's Continued Control over Decrescenzo's for More than Four Years after Her Exit
34. There is strong evidence that Scientology continued to exert its control over
DeCrescenzo for more than four years after she left the Sea Org. One would expect Scientology's
control to sustain itself for some time even if they had no further contact with DeCrescenzo. The
magnitude of their control while she was in Scientology, and the fact that this was the only way of
thinking she ever knew, would be difficult for DeCrescenzo to undo under any circumstances. Former
cult members who spent considerably less time in their organizations and experienced less totalistic
control report the struggles they have in "deprogramming" themselves after leaving.
3 5. Perhaps DeCrescenzo's deprogramming could have been accelerated if she had
received professional help. Post-Scientology counseling might have enabled her to systematically shift
out of her Scientology mindset sooner than she did. This, however, did not occur.
36. Rather, there is evidence that Scientology took steps to insure they remained in
control of DeCrescenzo. Some examples:
II
--They reinforced their previous threats by requiring her to sign an
affidavit and a release document before she was allowed to leave. As a further threat,
they videotaped her signing the document. The affidavit contained a listing of her
"supposed transgressions, including that I engaged in stealing in the past, that I stole
from the Church, that I failed to uphold my job duties, that I attempted suicide, and that
I did not hold the Church of Scientology responsible for anything that happened to me
during my time in the Sea Org."
20
DECLARATION OF ROBERT V. LEVINE, PH.D., 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-JUDG\Deciarations\2013-1()-08, Robert Levine.wpd
--She says she did not believe many of the statements she confessed to
on the affidavit but she "was so unstable that I would have signed anything in order to
be able to leave." This is easy to understand. She was confronted with the documents
within one day after swallowing the bleach in her suicide threat.
--She was required to certify a list of "undeniable benefits" that she had
received in Scientology-"as a staff member in the Sea Org, and as a participate of the
RPF." This was the used as the basis forthe $120,000 "Freeloader" bill, for services and
training she received while in Scientology, that she was later ordered to pay.
--She received a number of phone calls from Scientology members about
this bill. She eventually paid approximately $10,000 of these charges despite having
very little money at the time.
--It is my opinion that this fact alone-that DeCrescenzo paid $10,000 for
charges that any outsider would have recognized to be so unreasonable, as well as
legally unenforceable-testifies to Scientology's sustained control over DeCrescenzo's
sense of reality even after she quit.
--We see further evidence of this mindset in DeCrescenzo 's statement:
"The fact that members of the Church of Scientology issued this bill and continued to
call me to collect on it made me believe that the Church of Scientology was continuing
to keep tabs on me and to make sure that I did not take any actions that were
antagonistic of the Church."
--And, further, that "if I took any action against the Church of
Scientology (whether filing a lawsuit or even speaking negatively about the Church of
Scientology), it would use the statements in this affidavit against me, and that I would
be subjected to severe retribution, including significant financial penalties and loss of
my family."
--DeCrescenzo was also reminded of Scientology's presence in less
threatening ways. For example, Scientology personnel phoned her on numerous
occasions asking her to buy Scientology materials. She was certain that "these phone
21
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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calls were another way for the Church of Scientology to keep tabs on me and to make
sure that I was continuing to act in accordance with its wishes. A number of these
phone calls were so upsetting to me that I cried."
--In addition, Scientology continued to exploit her fears by manipulating
her to be part of the process. She recalls how "at least one Scientology representative
stood watch at my house while I called other members to collect money from them in
order to be able.to purchase Scientology materials that I could not afford myself." She
"believed that I was regularly being tested by the Church of Scientology." This was
undoubtedly true. In addition, I would add, these manipulations were a way of coercing
DeCrescenzo to acknowledge her subservience to Scientology. They reinforced her
belief in her powerlessness.
--DeCrescenzo remained an "active" Scientologist until July, 2008. Here
again, an outsider may find this decision difficult to comprehend. DeCrei;cenzo again
provides impressive insight into her behavior: "Looking back, I believe that I stayed
involved in the Church of Scientology out of fear that the Church of Scientology would
destroy me or my family as I observed members of the Church of Scientology do this
to other members who acted out against Scientology. I also believe that I acted
remained an active Scientologist because I believed that I would be cut off from my
family if I did not remain an active artd [a] "good standing" Scientologist. I observed
others leave the Church and be cut off from their family."
The Tipping Point
37. Self-deprogramming came gradually. $he reports: "It took months for me to
fully process what had happened to me and to begin to feel comfortable with the prospect of
challenging the Church of Scientology. While I began postiiig online about my experiences in
Scientology and the Sea Org in July 2008, I only made these posts anonymously and kept my feelings
about what happened during my time in the Sea Org very internalized. I was fearful if I posted under
my true identity, that the Church of Scientology would send someone to "handle" me, meaning that the
Church of Scientology would send someone to stop me from speaking out."
22
DECLARATION OF ROBERT V. LEVINE, PH.D., 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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-P\Cases\9527\SUM-JUDG\Declarations\2013-10-08, Robert Levine.wpd
--In Mid-June/July, 2008 DeCrescenzo discovered an "Ex-Scientologist"
web page on her mother's computer and confronted her about it. A few days later her
parents confessed to having doubts about Scientology, said they were no longer
Scientologists and for the very first time encouraged her to explore material not
approved by Scientology. It was not until then--more than four years after leaving
Scientology--that DeCrescenzo appears to have reached a tipping point in her ability
to reflect clearly and independently about Scientology.
--She also experienced an emotional shift: "This was the first time that
I felt safe in openly evaluating and questioning what had happened to me during my
time in the Sea Org. At all times prior to this, I believed that I would lose my family if
I openly questioned or challenged what had happened to me because we were forbidden
by the Church of Scientology from doing anything negative or antagonistic to the
Church. Additionally, at all times prior to this, I believed and feared the retribution that
the Church of Scientology had threatened me with (including financial penalties)
because I had been forbidden from reviewing or even considering anything contrary to
the Church of Scientology or its representations."
CONCLUDING COMMENTS
38. In summary, DeCrescenzo was raised in Scientology, socialized in Scientology
and her life was totalistically controlled by Scientology. Her energy and hope for achieving a better
alternative was undermined by a multiplicity of physical, social and psychological threats from
Scientology. She was made to believe that leaving or criticizing Scientology would have been
extremely costly even if she'd been prepared with the skills and knowledge to lead an alternative life,
which the entirety of her experience in Scientology had convinced her she was not.
39. In this document, I have presented my analysis of how DeCrescenzo was
manipulated and socialized by Scientology to a point where she lost her ability to make clear,
independent decisions about the reality she was confronted with. This is not to say that independent
thinking was impossible. Psychologists understand that, even under the most intense pressures,
23
DECLARATION OF ROBERT V. LEVINE, PH.D., IN SUPPORT OF PLAINTIFF'S OPPOSITION TO
DEFENDANTS' JOINT MOTION FOR SUl\1MARY JUDGMENT ON THE GROUND THAT THE STATUTES
OF LIMITATIONS BAR THE ACTION
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VITA
ROBERTV. LEVINE
Address: (Office) Department of Psychology
California State University, Fresno
Fresno, California 93740-0011
Phone: 559/278-2045
FAX: 559-278-7910
E-mail: robertle@csufresno.edu
Website: http://www.boblevine.net
Born: August 25, 1945 in Brooklyn, New York
EDUCATION
B.A. University of California at Berkeley, 1967
M.S. Florida State University, 1969 (clinical psychology)
Ph.D. New York University, 1974 (personality and social psychology)
ACADEMIC EXPERIENCE
1973-pres. Professor of Psychology, California State University, Fresno
2004-2005 Associate Dean, College of Science and Mathematics, CSU Fresno
1990-96 Chair, Department of Psychology, California State University, Fresno
VISITING POSITIONS
2012 Scholar-in-Residence, Institute of Advanced Studies, Durham University (UK)
2009 Visiting Scholar in Residence, The Canadian Centre for Architecture, Montreal
1994 Visiting Professor, Department of Psychology, Stockholm University
1976-77
Visiting Researcher, Sapporo Medical College, Sapporo, Japan
Visiting Professor, Universidade Federal Fluminense, Niteroi, Brazil. (Latin
American Teaching Fellowship)
A WARDS/HONORS
C! 2012-13 President, The Western Psychological Association
2012- Appointed by the Prime Minister of Bhutan to serve on the International
Expert Working Group, the United Nations The Gross National Happiness Project.
2008- Fulbright Specialist Program
2007 Western Psychological Association Outstanding Teacher of the Year Award (WPA)
2007 Provost's Award: University Outstanding Teacher of the Year (California State
University, Fresno)
2007 Awarded Fellow status in the Western Psychological Association
2007 Awarded Fellow status in the American Psychological Association (via Division One:
General Psychology)
2001 Honorary Membership, Golden Key International Honor Society
2000 Outstanding Professor of Psychology Award (California State University, Fresno Psi
Chi chapter
2000, 2001, 2003 California State University, Fresno nominee for Carnegie Foundation U.S.
Professor of the Year
1999 German translation of A Geography of Time named "Non-fiction Book of the Year" by
the German science magazine Bild der Wissenschaft
1998, 1999, 2000 and 2002 Selected as California State University, Fresno nominee for the
CSU Stanley Wang Award in the area of Behavioral Sciences and Public Service
1998 Otto Klineberg Intercultural and International Relations A.ward (for book: A Geography
of Time)
1997 Honorary Membership, Phi Kappa Phi Honor Society
1990 Meritorious Performance & Professional Promise Award (California State University,
Fresno)
;'::"1 1990 University Outstanding Professor of the Year (California State University, Fresno)
r-
'
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;-1
'f' ....
"
: ...
1989
1986
Distinguished Psychologist of the Year (voted by the San Joaquin Psychological
Association)
Meritorious Performance & Professional Promise Award (California State University,
Fresno)
i(i
~
-;';')
.........
1986 Outstanding Professor of Psychology Award (California State University, Fresno Psi
Chi chapter)
1980 Outstanding Professor of Psychology Award (the first year this was awarded)
(California State University, Fresno Psi Chi chapter)
NA TI ON AL/INTERN A TI ON AL PROFESSIONAL POSITIONS
2012-13 President, The Western Psychological Association
2007-pres. Editorial Board, Time Studies, published by The Portuguese Time Association.
2007-pres. Advisory Council, Campus Peace Centers (United Nations NGO)
2005-pres. Advisory Board, Emotion, Stress and Health Research Center, Doshisha
University, Kyoto, Japan.
2000-pres. Senior Advisory Board, International Institute of Occupational and Mental
Health, Diisseldorf, Germany.
1999-pres. Editorial Board, Journal Management Asia
1999-2001 Steering Committee, Society for the Advancement of Social Psychology
Committee on Urban Initiatives Network (APA Division 8 representative),
American Psychological Association
1998 Consultant, Smithsonian Museum of American History (Project title: About
Time)
1995-97 West Coast Regional Coordinator, Council of Undergraduate Psychology
Programs
1990-pres. Western Psychological Association Council of Representatives
1988-1994 Steering Committee, Society for the Advancement of Social Psychology
(Representative of organization to the American Psychological Society)
BOOKS
2008
PUBLICATIONS
Levine, R., Rodrigues, A., & Zelezny, L. (Eds.) (2008). Journeys in Social Psychology.
New York: Psychology Press.
'
2003 Levine, R. The Power of Persuasion: How We're Bought and Sold (2003). Hoboken,
NJ: John Wiley & Sons. (Translated into seven languages).
1999 Rodrigues, A., & Levine, R. (Eds.) (1999). Reflections on One Hundred Years of
Experimental Social Psychology. New York: Basic Books.
1997 Levine, R. (1997). A Geography of Time. New York: Basic Books. (Translated into
seven languages).
ARTICLES AND CHAPTERS
2013 Levine, Robert (2013). The social psychology of persuasion. In E. Diener & R.
Biswas-Diener (Eds), Noba textbook series: Psychology. Champaign, IL: DEF
Publishers. DOI: April, 2013, www.nobaproject.com
4
Levine, Robert (2013). Time and culture. In E. Diener & R. Biswas-Diener (Eds),
Noba textbook series: Psychology. Champaign, IL: DEF Publishers. DOI: April, 2013,
www.nobaproject.com
Reysen, S. & Levine, R. People, culture, and place: An integrative approach to
predicting helping toward strangers (2013). In: Renfrow, Jason, Geographical
Psychology. Washington, D.C.: The American Psychological Association Press, 241-
260.
2012 Levine, R. (2012, June). Review of: "Split-Second Persuasion" by Kevin Dutton
(Houghton Mitnin Harcourt, 2011). Choice Reviews.
2010 Levine, R. (2010, December). Review of: "The Social psychology of power," ed. by
Ana Guinote and Theresa K. Vescio (Guilford, 2010). Choice Reviews, 48 (4).
2009 Knapfo, A. Schwartz, S., & Levine, R. (2009). Helping strangers is lower in
embedded cultures. Journal of Cross-Cultural Psychology, 40, 875-9.
Levine, R. (2009). Review of: "Envy: theory and research," ed. by Richard H. Smith
(Oxford, 2008). Choice Reviews, 46(1).
Levine, R. (2009). Review of: "The empathy gap: building bridges to the good life
and the good society" by J. D. Trout (Viking, 2009). Choice Reviews, 46 (June).
Levine, R. (2009). Review of: "The Psychology of goals, ed. by Gordon B.
Moskowitz and Heidi Grant (Guilford, 2009). Choice Reviews, 46 (August).
\) 2008 Levine, R., Reysen, S., & Ganz, E. (2008). The kindness of strangers revisited: A
comparison of 24 U.S. cities. Social Indicators, 85, 461-481.
Levine, R. (2008, Jan.-Feb.). Keeping Time. SuperConsciousness, 2, 18-21.
Levine, R. (2008, April). Time: A world of differences. Toda Via, 18, 8-15.
Levine, R. (2008). Review of "Integrity: doing the right thing for the right reason" by
Barbara Killinger. Choice Reviews, 45(3).
2007 Levine, R. (2007). Time, money and the cultural divide. Chapter in E. Araujo, A.
M. Duarte and R. Ribeiro (Eds.). E 0 Tempo, as Culturas e as Instituicoes.
Lisbon: Edi95es Colibri, pps.11-24.
Levine, R. (2007, Sept.-Oct.). The evil that men do: Review of "The Lucifer Effect"
by Philip Zimbardo. American Scientist, 95, 440-442.
Levine, R. (2007). Review of "Size matters: how height affects the health, happiness,
and success ofboys--and the men they become" by Stephen S.Hall. Choice Reviews,
44(7).
2006 Levine, R. (2006, March). Time and culture. Prometeo, 24, 14-23.
2005 Levine, R. and Glassel, R. (2004, December). A village of hope. Newsletter of the
NGO Committee on Human Settlements, no. 2, 5.
Levine, R. (2005). Notes of a waiting watcher. En Attente: Casino Luxembourg
catalog, 14-24.
Levine, R. (2005). A geography of busyness. Social Research, 72, 355-370.
Levine, R. (2005). Keeping time. Geo Wissen, 36, 142-152.
2004 Van de Vliert, E., Huang, X., & Levine, R. (2004). National wealth and thermal
climate as predictors of motives for volunteer work. Journal of Cross-Cultural
Psychology, 35, 65-73.
Levine, R., Fast, N., & Zimbardo, P. (2004). The power of persuasion: A field
exercise. Teaching of Psychology, 31, 136-138.
Levine, R. (2004). Milgram's progress: Review of"The Man Who Shocked the
World" by Thomas Blass. American Scientist, 93, 368-70 .
5
. () 2003 Levine, R. (2003). Is time really money? StadtAnsichten, 6, 60-63.
[.)
\.=,)
Levine, R. (2003). Measuring helping behavior across cultures. In W. J. Lonner, D. L.
Dinnel, S. A. Hayes, & D. N. Sattler (Eds.), Online Readings in Psychology and
Culture (Unit 15, Chapter 9), Center for
Cross-Cultural Research, Western Washington University, Bellingham, Washington
'.
,,1
1''"
USA.
Levine, R. (2003). Social psychology. Encyclopedia Americana. Grolier online
encyclopedia, http://go.grolier.com/.
Levine, R. (2003). The kindness of strangers. American Scientist, 91, 226-233.
Levine, R. (2003). Cults. In E. Hickey (Ed.), Encyclopedia of Murder and Violent
Crime. Thousand Oaks, Ca.: Sage., 106-111.
2002 Kirkcaldy, B.D., Trimpop, R., & Levine, R. (2002) The impact of work hours and
schedules on physical and psychological well-being in medical practises. European
Psychologist, 7, 116-124.
Levine, R. (2002). Does money make us happy? Net and Books, 3, 76-79.
2001 Kirkcaldy, B., Furnham, A., and Levine, R. (2001). Attitudinal and personality
correlates of a nation's pace of life. Journal of Managerial Psychology, 16, 20-34.
Levine, R. (2001, February). Beware the illusion of vulnerability. Net and Books, 1,
24-27.
Levine, R., Norenzayan, A., & Philbrick, K. (2001). Cross-cultural differences in
helping strangers. Journal of Cross-Cultural Psychology, 32, 543-560.
2000 Levine, Robert (2000). Time talks, with an accent. Chapter in: Joke Brouwer (ed.),
Machine Times. Rotterdam: NAI PublishersN2_0rganisatie, pps. 134-149.
6
Kirkcaldy, B.D., Levine, R., & Shephard, R.J. (2000). The impact of working hours on
physical and psychological health of German managers. European Review of Applied
Psychology, 50. 443-449.
1999
1998
Levine, R. & Norenzayan, A. (1999). The pace of life in 31 countries. Journal of
Cross-Cultural Psychology, 30, 178-205.
Levine, R., Norenzayan, A. & Klicperova-Baker, M. (1999). Civility in a cross-
cultural perspective. Chapter in: Martina Klicperova-Baker (Ed.), Ready for
Democracy?: Civic Culture and Civility with a Focus on Czech Society, Prague:
Academy of Sciences of the Czech Republic, pps.161-184.
Levine, R. (1999, December 30th). Confessions of a numbers man (translated as:
Bekenntnisse eines zahlenmenschen ). Die W eltwoch, 52, 62-63.
Levine, R. (1998) Measuring the Silent Language. Chapter in: Singelis, T. (Ed.),
Teaching about Culture, Ethnicity, and Diversity: Exercises and Planned Activities,
;1:""'!
1-
: ...,
7
Newbury Park, CA: SAGE publications, 29-38.
Levine, R. Living on Event Time. Detours, on-line magazine published by the Illinois
Humanities Council, http://www.prairie.org. (Adapted from my book, A Geography of
Time).
Levine, R. (1998). Social psychology in Sweden: An interview with Anne-Sofie
Rosen. Contemporary Social Psychology, 18, 75-79.
Levine, R. (1998). Fingerprints of time (translated as: Fingerabdrucke der zeit).
Zeitschrift fuer KulturAustausch, 24-26.
Levine, R. (1998). Time or money--the great balancing act (translated as: Zeit oder
geld--der grosse ausgleichsakt). Gdi Impuls, 4, 3-14.
1997 Levine, R. (1997, Sept-Oct.). How to tell time like a cow. (Adapted from my book, A
Geography of Time). Utne Reader, 79-80.
Levine, R. (1997, November). The pace of life in 31 countries. (Adapted from my
book, A Geography of Time). American Demographics, 1.2, 20-29.
1996 Levine, R. (1996). Toward a psychology of multitemporality. Chapter in: Takekawa,
T. (Ed.) Writings in Honor of Professor Yoshio Sugiyama. Sapporo, Japan: Sapporo
Medical University, 161-167.
Levine, R. (1996). Cultural differences in the pace of life. Chapter in: Helfrich, Hede
(Ed.) Time & Mind. Gottingen, Germany: Hogrefe & Huber, 119-140.
1995 Levine, R., Sato., S., Hashimoto, T. & Verma, J. (1995). Love and marriage in eleven
cultures. Journal of Cross-Cultural Psychology, 26, 554-571.
1994
Levine, R. (1995, July 29). Rude? Yes, you are. New York Times: Op-Ed Feature,
p.19.
Levine, R. (1994). Cultural differences in time. In Macey, S.L. (Ed.) Encyclopedia of
Time. New York: Garland, 148-150.
Levine, R., Martinez, T., Brase, G. & Sorenson, K. Helping in 36 U.S. Cities (1994).
Journal of Personality & Social Psychology, 67, 69-81.
Levine, R. (1994-95, Winter). Cities with heart. The Responsive 59-
67.
.C! 1993 Levine, R. (1993, April). Seeking the golden thread. Review of Bond, Michael,
Beyond the Chinese face: Insights from psychology. Contemporary Psychology, 38,
365-6.
Levine, R. (1993). Social Psychology in India: An interview with Jyoti Verma.
Contemporary Social Psychology, 16, 26-29.
Levine, R. (1993, February). Is love a luxury?. American Demographics, 27.
Levine, R. (1993). Social Psychology in Nepal: An interview with Sarvagya Narayan
Shrestha, Murari Prasad Regmi and Ayan Bahadur Shrestha. Contemporary Social
Psychology, 11, 4-7.
Gonzalez, A., Aguilar-Gaxiola, S. & Levine, R. (1993). Radio bilingue smoking
survey. In: Canfield, M & Canfield, J. (Eds.) A Collection of Psychological Scales.
Bartlesville, OK: Research, Evaluation and Statistics, pp. 90-103.
Levine, R. (1993, October). Cities with heart. American Demographics, 46-54.
1992 Levine, R. (1992, April). A hollow brass ring. Intersect, 17-20.
Levine, R. (1992, June). Why isn't Japan happy?. American Demographics, 58-60.
Levine, R., Aguilar-Gaxiola, S. & Gonzalez, A. (1992). Social Psychology in Brazil:
An interview with Aroldo Rodrigues. Contemporary Social Psychology, .Ll_, 2-5.
1991 Levine, R. (1991, June). Prosocial behavior: For better and for worse, the state of the
art. Contemporary Social Psychology, .Ll_, 68-69.
1990
Levine, R. (1991, September). Social psychology in Hong Kong: An interview with
Michael Harris Bond. Contemporary Social Psychology, .Ll_, 78-83.
Mouanoutoua, V., Capaletti, G., Brown, L. & Levine, R. (1991, October). A Hmong
adaptation of the Beck Depression Inventory. Journal of Personality Assessment, 57,
309-322.
Levine, R., Sievers, R. & Moriyama, M. (1991, November). Life satisfaction in Japan
vs. the U.S.A.: 1978-1990. Resources in Education, ED333316.
Levine, R., Lynch, K., Miyake, K., & Lucia, M. (1990). The type A city: Coronary
heart disease and the pace oflife, Journal of Behavioral Medicine, 12, 509-524.
Levine, R. (1990, March). Angling for more of the pie: The APS summit in Tucson.
Contemporary Social Psychology, 14, 7-8.
Levine, R. (1990, September-October). The pace of life and coronary heart disease.
American Scientist, 78, 450-459.
8
9
(Reprinted in a number of sources, including: Dushkin's Annual Editions: Psychology;
Dushkin's Annual Editions: Personal Growth and Behavior, and Mc Whorter, K.
(1993) The Writer's Express (Houghton-Mifflin); Also, reprinted in translation in
several sources, including (in Swedish): Levine, R. (1994, April). Livets tempo.
Forskning och Framsteg, J_, 43-45.).
1989 Levine, R., Miyake, K., & Lee, M. (1989). Places rated revisited: Psycho-social
pathology in metropolitan areas. Environment and Behavior, 21, 531-553.
(Cited as one of eight "Landmark Publications on Urban Quality" in Urban Quality
Indicators ( 1996), l, p.10).
Levine, R. (1989, October). The pace of life, Psychology Today, 42-46.
(Reprinted in several sources, including: Dushkin's Annual Editions, 1991: Urban
Society).
1988 Levine, R. (1988, April). The social psychology of a biology watcher: A review of
Lewis Thomas's The Lives of a Cell, Contemporary Social Psychology, .U, 174-5.
Levine, R. (1988). The pace oflife across cultures. Chapter in McGrath, J. (Ed.) The
Social Psychology of Time: New Perspectives. Newbury Park, CA: SAGE
publications, 39-60.
Levine, R. (1988, November). City stress index: 25 best, 25 worst, Psychology
Today, pp. 52-58.
1987 Levine, R. (1987, April). The waiting game: Power has its privilege. Psychology
Today, 24-33.
1986
(Reprinted in several sources, including Dushkin's Annual Personal Growth
& Behavior 1989/90.)
Levine, R. (1987), July). A new social psychology? (Review of White, G., &
Kirkpatrick, J., Person, Self & Experience: Exploring Pacific Ethnopsychologies.
Contemporary Psychology, 623-624.
Levine, Robert (1986, November). Lessons from the limelight. APA Monitor, 4-5.
(Reprinted in several sources, including: The St. Louis Journalism Review, 1987.)
Levine, Robert (1986). Coping with the silent language in cross-cultural research. -
Cross-National Research Papers, February, 1987, 27-33.
1985
Levine, R. (1985). Pace of life on four continents. Social Science Quarterly.
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Levine, R, & Wolff, E. (1985, March). Social time: The heartbeat of culture.
Psychology Today, 28-35 .
(Reprinted in several sources, including: Goldstein, E. (Ed.) SIRS Science: Life


f.)
Science, 1985; and, Dushkins Annual Editions: Anthropology, 1989/90.)
Levine, R. (1985, December). It wasn't the time of my life. Discover, 66-71.
(Reprinted in several sources, including: Contemporary Social Psychology, 1988, 1_,
168-171; and in: Henslin, J.M. (Ed.) ( 1987) Down to Earth Sociology, The
Free Press.)
1984 Levine, R.V., & Bartlett, K. (1984). Pace of life, punctuality and coronary heart
disease in six countries. Journal of Cross-Cultural Psychology, .Ll., 233-255.
10
Levine, R. (1984, December). Cross-cultural studies: A mad world. AP A Monitor, 5-
6.
1983 Levine, R.V. (1983, January). An interdisciplinary course studying psychological
issues through literature. Teaching of Psychology, lQ, 214-216.
(Reprinted in Benjamin, L., Daniel, R., & Brewer, C. (1985). Handbook for teaching
introductory psychology, L. Erlbaum & Assoc: New Jersey.
1982 Levine, R., Gillman, M., & Reis, H. (1982). Explaining sex differences in achievement
attributions. Sex Roles: A Journal of 455-466.
1981 Levine, R. & West, L. (1981). Attitudes toward adoption and child-bearing by
American and Brazilian students. Population and Environment, 1_, 3-10.
1980 Levine, R., West, L., & Reis, H. (1980). Perceptions oftime and punctuality in the
United States and Brazil. Journal of Personality and Social Psychology, 38(4),
541-550.
1979 Levine, R., & Uleman, J. (1979). Self-attributions as a function of perceived locus of
control and self-esteem. Personality & Social Psychology Bulletin, .2_, 69-72.
1978
1977
1976
Levine, R., & West, L. (1979). Attitudes toward women in the United States & Brazil.
Journal of Social Psychology, 108, 265-266.
Levine, R.V. (1978). A transcultural study of maturity. (Review of Health, Douglas,
Maturity and Competence: A Transcultural View). Contemporary Psychology, 23,
653-654.
Levine, R.V. (1977). An interdisciplinary approach to the introductory psychology
course. Teaching of Psychology, 1_, 132-134.
Levine, R., Reis, H., Sue, E., & Turner, G. (1976). Fear of failure in males: A more
salient factor than fear of success in females? Sex Roles: A Journal of Research, 2.,
389-398.
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11
Levine, R., & West, L. (1976). Attraction as a function of boasting, self-apology, and
credibility of actor. Psychological Reports, 38, 1243-1246.
1975 Levine, R.V., & Megargee, E.I. (1975). Prediction of academic success with the
MMPI and Beta in a correctional institution. JSAS Catalog of Selected Documents in
Psychology , , 343.
1971 Megargee, E.I., Parker, G.V., & Levine, R.V. (1971). Relationship of familial and
social factors to socialization in middle-class college students. Journal of Abnormal
Psychology, 77, 76-89.
1970 Megargee, E.I., Price, A.C., Frohwirth, R., & Levine, R.V. (1970). Time orientation
of youthful prison inmates. Journal of Counseling Psychology, 11, 8-14.
1969 Levine, Robert V. (1969). The MMPI and Revised Beta as predictors of academic and
vocational success in a correctional institution. F.C.I. Research Reports, l, whole issue
no. 3.
INVITED LECTURES AND PRESENTATIONS (selected)
2013 Levine, R. (2013, April). Time and persuasion. Invited lecture to the Apple Computer
Design Group, Cupertino, CA ..
Levine, R. (2013, April). A geography ohime. Presidential address, the annual
meeting of the Western Psychological Association, Reno, NV.
Levine, R. (2013, May). Invited series oflectures on the topics ohime and persuasion
at the University of Sao Paulo, Brazil.
2012 Levine, R. (2012, January). Time. Invited lecture at the Rome Science Festival, Italy.
2011
Levine, R. (2012, March). On Time. Keynote lecture (Psi Chi), Dominican
University, San Rafael, CA.
Levine, R. (2012, October). A Geography of Time. Public Lecture Series, Institute of
Advanced Studies, Durham University (UK).
Levine, R. (2011, March). The Power of Persuasion. Invited lecture series at the
Osher Institute, Fresno, CA.
Levine, R. (2011, December). A Geography of Time. TEDx, Riverside, CA.
'', 2010 Levine, R. (2010, April). Rating cities. Invited lecture on the topic of Urban
Psychology, Fordham University, NYC.
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2009 Levine, R. (2009, March). Invited series oflectures on time and culture at the
Interdisciplinary College (IK) at Lake Mohne, Germany.
Levine, R. (2009, April). Invited lecture on field research in social psychology, Bard
College, NY.
2008 Levine, R. (2008, November). About time. Invited lecture at the Osher Institute,
Fresno, CA.
Levine, R. (2008). Invited lecture on cross-cultural psychology, Beloit College.
Levine, R. (2008, April). The Kindness of Strangers. Invited "Teaching Award
Address" at the meeting of the Western Psychological Association, Irvine, California.
2007 Levine, R. (2007, May). A geography of time. Invited lecture, Second International
School on Mind, Brain and Education, Erice, Sicily.
2006 Levine, R. (2006, March). Time and culture. Keynote address, Minnesota
Undergraduate Psychology Conference.
Levine, R. (2006, March). Helping and altruism in cities. Invited presentation to the
United Nations NGO Committee on Human Settlements, New York City.
Levine, R. (2006, November). Time. Invited lecture at the University ofMinho,
Portugal.
Levine, R. (2006, October). Time and perinatology. Invited lecture at the NIH
Perinatology Research Branch, Detroit, Ml.
2005 Levine, R. (2005, April). All I really need to know about social psychology I learned
as a used car salesman. Invited presentation at the meeting of the Western
Psychological Association, Portland, Oregon.
Levine, R. (2005, May). Time and the pace oflife. Keynote address, School of
Technology Studies, Eastern Michigan University.
Levine, R. (2005, June). A village of hope: An experimental community of homeless
people. Invited presentation to the United Nations NGO Committee on Human
Settlements, New York City.
:.D 2004 Levine, R. ( 2 0 0 ~ , May). Helping and urban psychology. Invited lecture at Fordham
University, New York City.
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Levine, R. (2003, May). A geography ohime. Invited address at Eurostadt Museum,
Wolfsburg, Germany .
2000 Levine, R. (2000, April). What's a boy to do? Form, content and plenty of luck.
Invited "Last Lecture," presented at the meetings of the Western Psychological
Association, Portland, Or.
Levine, R. (2000, May). Time and culture. Invited lecture on the topic, "Time
Matters," Stanford University.
Levine, R. (2000, November). Time talks, with an accent. Invited lecture at Dutch
Electronic Arts Festival (DEAF), Rotterdam, The Netherlands.
1999 Levine, R. (1999). Time and the pace of life. Invited guest lecture, Stanford
University, CA.
Levine, R. (1999, October). A geography of time (Geographie der zeit). Invited
lecture, Theater Neumarkt, Zurich Switzerland ..
13
Levine, R. (1999, October). A geography of time (Geographie der zeit). Invited
lecture by the Ministery of Culture of the State of North Rhine Westfalia at the NRW-
Forum Kultur und Wirtschaft Museum, Dusseldorf, Germany.
Levine, R. (1999, October). A geography of time (Geographie der zeit). Keynote
address, Millennium Tage conference, Kassel, Germany.
1998 Levine, R. (1998, July). Time. Invited address at the Marlboro Project, Sundance, UT.
Levine, R. & Norenzayan, A. (1998, June). The pace oflife and well-being in seven
Asian countries. Invited symposium on Time and Society in Asia at the Nordic
Institute of Asian Studies, Copehagen, Denmark.
1997 Levine, R. (1997, July). A geography of time. Invited address at Smithsonian
Museum speaker series, Washington, D.C.
1994 Levine, R. (1994, December). Social time: The heartbeat of culture. Invited
presentation at a symposium on Time and Mind, Regensburg, Germany.
1991
1987
Levine, R. (1994, August-October). Invited lectures on culture and social psychology.
Stockholm University, Sweden.
Levine, R. (1991, June). A look at the diversity of cultures. Keynote address at the
Summer Institute on Aging: A Multi-Cultural Happening, Fresno, CA.
Levine, R. (1987, July). Cross-cultural issues in health psychology. Invited lecture,
Nippon Kokan, Tokyo, Japan.
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CONFERENCE PRESENTATIONS AND OTHER REPORTS
2013 Armendariz, A., Kosloff, S., & Levine, R. (2013, April).Culture as a mediating
variable on self-handicapping. Poster presented at the annual meeting of the Western
Psychological Association, Reno, NV.
Desiga, A., Kosloff, S., & Levine, R. (2013, April). Using situational awareness to
improve empathy and perspective taking skills. Poster presented at the annual meeting
of the Western Psychological Association, Reno, NV.
Lichtenstein, R., Wagoner, J., & Levine, R. (2013, April). Teaching psychology
online: Exploration and analysis of online education resources. Poster presented at the
annual meeting of the Western Psychological Association, Reno, NV.
Saksouk, M., Kosloff, S., & Levine, R. (2013, April). An intervention using self-
counterstereotyping to reduce the negative effects of stereotype threat. Poster
presented at the annual mee.ting of the Western Psychological Association, Reno, NV.
2012 Schumacher, N. & Levine, R. (2012, April). Effects of point-of-view and subjective
well-being on perception of daily hassles. Poster presented at the annual meeting of
the Western Psychological Association, San Francisco, CA.
2011
2010
Lichtenstein, R. & Levine, R. (2012, April). Cultural differences in perceptions of self-
concept consistency. Poster presented at the annual meeting of the Western
Psychological Association, San Francisco, CA.
Hagy, G., Fabros, M., Levine, R., Sato, S., Verma, J., & Iglesias, F. (2012, April.
Consistency of self from kin versus non-kin perspectives. Poster presented at the
annual meeting of the Western Psychological Association, San Francisco, CA.
Wagoner, J. & Levine, R. (2011, May). Non-religious attributions to ambiguous
situations. Poster presented at the annual meeting of the Western Psychological
Association, Los Angeles, CA.
Hagy, G., Fabros, M., Levine, R., Verma, J., O'Leary, V. (2011, May). Consistency
of self-perspective across four countries. Poster presented at the annual meeting of the
Western Psychological Association, Los Angeles, CA.
Ying, T. S. & Levine, R. Individual differences in transmitting negative gossip. Poster
presented at the annual meeting of the American Psychological Association, San
Diego, CA.
[._) 2008 Nicolaides, V. & Levine, R. (2008, April). Cross-cultural differences in helping: The
Middle East and Europe. Poster presented at the meeting of the Western Psychological
Association, Irvine, CA.
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Levine, R. (2008, August). The future ohime. Invited symposium at the meeting of
the American Psychological Association, Boston, MA.
15
2006 Levine, R. (2006, April). The power of persuasion. Invited presentation at the
meeting of the Western Psychological Association, Palm Springs, California.
Pesin, Lily & Levine, R. (2006, April). Predictors of post college success and well-
Being. Poster presented at the meeting of the Western Psychological Association,
Palm Springs, California.
Mendez, Maria & Levine, R. (2006, April). The availability of social support for
homeless people. Poster presented at the meeting of the Western Psychological
Association, Palm Springs, California.
2005 Levine, R. (2005, April). All I really need to know about social psychology I learned
as a used car salesman. Invited presentation at the meeting of the Western
Psychological Association, Portland, Oregon.
2004 Fast, N., Levine, R., Halpern, D., & Bell, Melissa. (2004, January). Stereotyping of
powerholders: the consequences of perceptions of competence and warmth. Paper to
be presented at the annual meeting of the Society of Personality and Social
Psychology, Austin, Texas.
2003 Canosa, P. & Levine, R. (2003, April). The reciprocity norm and charitable donations.
2002
Paper presented at the meetings of the Western Psychological Association, Vancouver,
Canada.
Fast, N. & Levine, R. (2003, April). Effects of influence on users: coercion,
manipulation, and rational argument. Paper presented at the meetings of the Western
Psychological Association, Vancouver, Canada.
Fast, N. & Levine, R. (2003, May). Situational impact on choice of manipulative and
coercive influence techniques. Paper presented at the meetings of the American
Psychological Society, Atlanta, Ga.
Fast, N. & Levine, R. (2003, July). First and third person evaluations of social power
strategies. Paper presented at the meetings of the International Society for Political
Psychology, Boston, Ma.
Horton, S. & Levine, R. (2003, April). Persuasion and advertising: teaching resistance
to unhealthy food choice. Paper presented at the meeting of the Western
Psychological>Association, Vancouver, Canada.
Fast, N., Gerber, J. & Levine, R. (2002, April). Teaching about vulnerability to
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persuasion. Paper presented at the meetings of the Western Psychological
Association, Irvine, Ca.
16
2000 Levine, R. (2000, April). What's a boy to do? Form, content and plenty of luck.
Invited "Last Lecture," presented at the meetings of the Western Psychological
Association, Portland, Or.
Burgos, K., Rodriguez, A., & Levine, R. (2000, April). Gaining charitable
contributions: When "It's for a good cause." Paper presented at the meetings of the
Western Psychological Association, Portland, Or.
1999 Levine, R., Norenzayan, A., & Philbrick, K. (1999, July). Helping in 23 countries.
Paper presented at the meetings of the International Society for Political Psychology,
Amsterdam, The Netherlands.
Klicperova-Baker, M., Feieraend, I., Hofstetter, C.R., Levine, R., & Kucerova, R.
(1999, July). Patterns of civility in the post-totalitarian democracies. Paper presented
at the meetings of the International Society for Political Psychology, Amsterdam, The
Netherlands.
1998 Williams, R.L, Chua, P., Rodriguez, A., Khoo, K., Levine, R., & Rodrigues, A. (1998,
April). Research trends spanning four decades of the Journal of Personality and Social
Psychology. Paper presented at the meetings of the Western Psychological
Association, Albuquerque, New Mexico.
1997 Levine, R. & Rodrigues, A. (1997, March) (co-organizers). One Hundred Years of
Social Psychology. Invited conference, Yosemite National Park, CA.
1994
Levine, R. (1997, April). Chair, Council of Undergraduate Psychology Program
(CUPP) invited symposium on Teaching Social Action. Symposium presented at the
meetings of the Western Psychological Association, Seattle, WA.
Levine, R. (1997, November). Time and well-being. Invited address at the First
Conference of the International Society of Quality of Life Studies in Charlotte, North
Carolina.
Soles, J. R., Eyssell, K., Norenzayan, A., & Levine, R. (1994, April). Personality
correlates of the pace of life. Paper presented at the meetings of the Western
Psychological Association, Kona, Hawaii.
Norenzayan, A., & Levine, R. (1994, April). Helping in 18 international cities. Paper
presented at the meetings of the Western Psychological Association, Kona, Hawaii.
Levine, R. (Chair), Zimbardo, P., Block, R. & Brislin, R. (1994, April). Symposium
on Time and Culture. Paper presented at the meetings of the Western Psychological

Association, Kona, Hawaii.
Levine, R. & Ritter, J. (1994, April). Preparing students for graduate study. Paper
presented at a symposium on undergraduate teaching at the meetings of the Western
Psychological Association, Kona, Hawaii.
Levine, R. (1994, December). Social time: The heartbeat of culture. Invited
presentation at a symposium on Time and Mind, Regensburg, Germany.
17
1993 Levine, R. (1993, April). Conducting experiments in real-life settings. Invited
presentation at a symposium on Teaching research methods at the annual meeting of
the Western psychological Association, Phoenix, AZ.
1992 Barnes, L., Levine, R. & Ludwig, M. (1992, May). The relationship of critical
thinking ability to scholastic aptitude. Paper presented at the annual meeting of the
Western psychological Association, Portland, OR.
1991
Moriyama, M., Levine, R. & Keough, J. (1992, May). Independence and well-being
among elderly Japanese and Japanese-Americans. Paper presented at the annual
meeting of the Western psychological Association, Portland, OR.
Levine, R. & Conover, L. (1992, July). The pace oflife scale: Development of a
measure of individual differences in the pace of life. Paper presented to the
International Society for the Study of Time, Normandy, France.
Levine, R. (Chair), Robinson, J., Jamner, J. & Jones, J., Symposium on Time and
Stress. Symposium and paper presented at the AP A/NIOSH/WHO et al. conference
on Stress in the 90's: A Changing Workforce in a Changing Place, Washington, D.C.,
November, 1992.
Sievers, R., Levine, R., & Moriyama, M. (1991, April). Life satisfaction in Japan vs.
the U.S.A.
Levine, R., Martinez, T., Brase, G. & Sorenson, K. (1991, April). Helping behavior in
36 U.S. cities. Paper presented at the annual meeting of the Western psychological
Association, San Francisco, CA.
Kelso, K., Newell, T. & Levine, R. (1991, August). Attribution ofresponsibility for
contracting AIDS. Paper presented at the annual meeting of the American
Psychological Association, San Francisco, CA.
., 1990
Levine, R. (1990, April). Invited participant on Forum on Exemplary Teaching.
American Association on Higher Education National Conference on Higher
Education, San Francisco, CA.
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Adams, V., Levine, R., Sato, S. & Hashimoto, T. (1990, April). Type A behavior,
time perspective and life satisfaction: Japan vs. the United States. Paper presented at
the annual meeting of the Western Psychological Association, Los Angeles, CA.
Levine, R. (1990, August). Social time: The heartbeat of culture. Paper presented as
part of an invited symposium on: Psychological time: Epistemic, Experimental, and
Social Explorations. Annual meeting of the American Psychological Association,
Boston, MA.
Levine, R. (1990, October). Cross-national issues in psychology. Invited symposium
at the Fifth Annual Mexico-United States Inter-university Symposium, CA.
1989 Levine, R., Lynch, K., Miyake, K., & Lucia, M. (1989, March). The Type A city:
Coronary heart disease and the pace of life. Paper presented at the Society of
Behavioral Medicine 10th Anniversary Meeting in San Francisco.
Levine, R. (1989, April). Cross-cultural issues in social time. Invited address
presented at the Third Annual Nursing Research Symposium: "Transcultural nursing:
Caring across cultures," Fresno, California.
Levine, R., Donnerstein, E., Kelley, H., Maslach, C., & Reis, R. (1989), April). The
future: What will psychologists be studying in 2001? Invited symposium presented at
the annual meeting of the Western Psychological Association, Reno, NV.
Levine, R. (1989, July). Social time and physical health. Paper presented at the
meetings of the International Society for the Study of Time, Glacier Park, Montana.
1988 Levine, R., Lynch, K., Miyake, K., & Lucia, M. (1988, June). The Type A city:
1987
Coronary heart disease and the pace of life. Paper presented at the Nag's Head
Conference on Social Factors in Health & Adjustment, Nag's Head, North Carolina.
Levine, R. (1988, October). Recent trends in employment in psychology in the USA.
Paper presented at the Third Annual Interuniversity Symposium, Guanajuato, Mexico.
Anderson, A., Miyake, K., Sanders, G., & Levine, R. (1987). Time perspective, Type
A behavior pattern and psychological well-being among college males. Paper
presented at the annual meeting of the Western Psychological Association, Long
Beach, CA.
Levine, R., Miyake, K., & Lee, M. (1987, March). A social pathology index of
metropolitan areas across the United States. Paper presented at the University of
Manitoba conference on applications of individual differences in stress and health
psychology, Manitoba, Canada.
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1986 Levine, Robert (1986, July). The pace of life across cultures. Paper presented at the
3rd annual conference of the Association for the Social Studies of Time, Totnes,
England.
Levine, R. (1986, May). Time and culture. Invited keynote address at the annual
Bullard Science Day, Fresno; CA.
1985 Levine, Robert (Chair) (1985, April). The drama of psychology. Symposium
presented with Philip Zimbardo and others at the Annual meeting of the Western
Psychological Association.
1984 Levine, R. (1984, June). Pace oflife on four continents. Paper presented at the Nag's
Head Conference on Natural Interaction, Nag's Head, North Carolina.
Saldana, L. J., Shanab, Mitri, and Levine, R. (1984). Estimations of Physical
Attributes: A Cross-Cultural Examination. Paper presented at the Annual Meeting of
the Western Psychological Association, Los Angeles, California.
1983 Levine, R. (1983, December). Teaching psychological issues through literature. Paper
presented at the Fifth National Institute on the Teaching of Psychology to
Undergraduates, Clearwater, Fla.
1982 Lucy, D., & Levine, R. (1982, April). Psychological androgyny, socioeconomic status
and life satisfaction in older and younger people. Paper presented at the annual
meeting of the Western Psychological Association, Sacramento.
Levine, R. & Bartlett, K. (1982, July). Concepts of time and punctuality, pace oflife
and the coronary-prone personality in Japan, Taiwan, Indonesia, Italy, England and the
U.S.A. Paper presented at the 20th International Congress of Applied Psychology,
Edinburgh, Scotland.
1979 Levine, R., & Salehi, M. (1979). Voting behavior: When will we exercise write-in
options? Paper presented at the Annual Meeting of the Western Psychological
Association.
1975
1974
Reis, H. T., & Levine, R. V. (1975, April). Obesity and hypnotic susceptibility. Paper
presented at the annual meeting of the Western Psychological Association.
Levine, Robert V. (February, 1974). Chairman of a symposium on social psychology
at the annual meeting of the California State Psychological Association.
Levine, Robert V. (1974, April). Attributions to success and failure as a function of
perceived locus of control and level of self-esteem. Paper presented at the annual
meeting of the Western Psychological Association.
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Worsley, K., Augusto, J., Moore, R., Wood, L., Zwetsloot, M., & Levine, R. (1974,
February). Fresno community attitudes toward women and the women's movement.
Paper presented at the annual meeting of the California State Psychological
Association.
1973 Levine, Robert V. (1973). Evaluation of Training in Nonviolent Action. New York,
New York: Quaker Project on Community Conflict.
1970 Levine, Robert V. (1970, January). A personality profile of patients in a geriatric
psychiatric outpatient program. Paper presented as part of a symposium on aging at
the annual meeting of the California State Psychological Association.
20
Shapiro, J. G., Levine, R. V. & Staff (1970, June). A Geriatric Psychiatric Outpatient
Project. San Francisco, California: Langley-Porter Neuropsychiatric Institute.
NEWSPAPER/MAGAZINE/MEDIA FEATURED STORIES
My work has been the subject of feature stories in a number of regional, national and
international outlets. Feature articles on my research and writing have appeared, for example, in
Newsweek, The New York Times Magazine, Parade, USA Today, OMNI, Psychology Today,
Discover, Utne Reader and many newspapers. I have been featured on many National Public
Radio Shows, including All Things Considered, Talk of the Nation and Radio Lab, and on a
number of national television shows, including The Discovery Channel, The Canadian Discovery
Channel, BBC Television and Radio, ABC World News, NBC Dateline, ABC PrimeTime, CNN
News, CNN Special Reports, Canal 4 (France) and the National Geographic network. Also,
versions of my own articles have been published as feature articles in many newspapers,
including The New York Times, The San Francisco Chronicle, The San Diego Union, The St.
Louis Journalism Review, The Sacramento Bee, and Business International.
GRANTS
I have received over 50 research, innovative teaching and performance awards and grants
ranging from $1,000 to $3,000, from the College of Science and Mathematics, and/or California
State University, Fresno
PROFESSIONAL MEMBERSHIPS
American Psychological Association (Fellow)
Western Psychological Association (Fellow)
Society for the Advancement of Social Psychology
Society for the Psychological Study of Social Issues
Society of Personality and Social Psychology
Society for General Psychology (Fellow)
International Society for the Study of Time
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COURSES TAUGHT
Regular catalog courses taught include:
-Introduction to Psychology
-Psychological Adjustment
-Personality
-Statistics
-Psychology of Aging (undergraduate and graduate)
-Social Psychology (undergraduate and graduate)
-Research Methods
New courses developed and taught:
-Social Psychology and Culture (undergraduate honors class)
-The Psychology of Close Relationships
-Consciousness and Awareness
-Psychology of Mind Control and Cults
-Field Experience in Social psychology (graduate)
-Seminar on the Social Psychology of Aging
-Freedom and Authority (a 15-unit lower division team taught course in -conjunction
with the departments of political science, philosophy and English).
-Psychological Issues through Literature (interdisciplinary team taught course in
conjunction with a member of the department of English).
21
-Supervised field experience in psychology (Now a regular department offering, this
course has placed students in volunteer positions with such organizations as Help in
Emotional Trouble, rape counseling, Hospice, Fresno juvenile hall, planned parenthood
and Comprehensive Youth Services).
CURRENT COMMUNITY POSITIONS
Poverello House (meals and services for the homeless), Board of Directors (1997-present);
Fresno Fire & Metal (a non-profit startup school of industrial arts serving under-privileged
youth), Board of Directors (2010-present)
REFERENCES
Dr. Thomas Breen, Department of Psychology, California State University, Fresno; Fresno,
93740-0011 (tel.: 559-278-2855; e-mail: tomb@csufresno.edu).
Dr. Jerry Burger, Department of Psychology, Santa Clara University, Santa Clara, CA 95053
(phone: 408-554-4489; e-mail: Jburger@scu.edu).
' Dr. Ara Norenzayan, Department of Psychology, University of British Columbia, 2136 West
<) Mall, Vancouver, BC V6T 1Z4 Canada (tel. (604) 827-5134; e-mail: ara@psych.ubc.ca).
Dr. Harry Reis, Department of Psychology, University of Rochester, Rochester, NY, 14627 (tel.:
: ...
716-2 7 5-8697; e-mail: reis@prodigal. psych.rochester .edu).
Dr. Philip Zimbardo, Department of Psychology, Jordan Hall Bldg. 420, Stanford University,
Stanford, CA, 94035-2099 (tel.: 415-725-2417; e-mail:philzimbardo@yahoo.com).
(Revised 9/13)
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-P\Cases\9527\SUM-JUDG\Declaralions\2013-10-08, Robert Levine.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 ROBERT v. LEVINE, PH.D., 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
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.
__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 off ices of
a member of this court, at whose direction service was made.
Executed on October 9, 2013, at Long Beach, California.
,----,______ I
Nina S. Vidal, Declarant
25
DECLARATION OF ROBERT V. LEVINE, PH.D., IN SUPPORT OF PLAINTIFF'S OPPOSITION TO
DEFENDANTS' JOINT MOTION FOR SUMMARY JUDGMENT ON THE GROUND THAT THE STATUTES
OF LIMITATIONS BAR THE ACTION
(J) I- - :;:
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aP\Cases\9527\SUM-JUDG\Declarations\2013-1 ()-08, Robert Levine.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
(Religious Technology Center)
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DECLARATION OF ROBERT V. LEVINE, PH.D., IN SUPPORT OF PLAINTIFF'S OPPOSITION TO
DEFENDANTS' ~ O I N T MOTION FOR SUMMARY JUDGMENT ON THE GROUND THAT THE STATUTES
OF LIMITATIONS BAR THE ACTION
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-P\Cases\9527\SUM-JUDG\Ceclarations\2013-Hl-08, Robert Levine.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 ROBERT v. LEVINE, PH.D., 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.
{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 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 October 9 2013 at Long Beach, California.

Nina S. Vidal, Declarant
27
DECLARATION OF ROBERT V. LEVINE, PH.D., 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-JUDG\Declarations\2013-10-08, Robert Levine.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)
-ooo-
John P. Blumberg, Esq.
7 Blumberg Law Corporation
444 W. Ocean Blvd., Suite 1500
8 Long Beach, CA 90802
(Plaintiff)
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(Updated August 23, 2012 jlp)
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DECLARATION OF ROBERT V. LEVINE, PH.D., 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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