Law oes OF Gary S. SoTER A PROFESSIONAL CORPORATION G23) 860-1909 February 25, 2015, VIA EMAIL AND US MAIL Karen de la Carriere 1935 N Serrano Avenue Los Angeles CA 90027-1621 Karendelae@aol,com Dear Ms. De la Carriere: [represent the Church of Scientology International. Your YouTube channel shows that you are in possession of videos which were stolen from the Church of Seientology by ‘your friend John Joseph, aka “Plain Old Thetan.” Mr. Joseph was under investigation by the U.S. Postal authorities in Tucson, Arizona for his thelts of videos and other documents. He died before that matter was resolved or civil action was brought against hhim by the Church, ‘The stolen documents include but are not limited to materials protected under U.S. and foreign copyright laws, confidential personnel data, intellectual property. trade secrets and related communications. ‘The stolen materials include the following ‘copyrighted videos which you published to the world on your YouTube channel after ‘your obvious receipt of them from Mr. Joseph: ‘www youtube com/watch?v=s0S-IVQBXdg ~ NEW YEAR EVENT 2009/10 ‘www youtube com/wateh?v=O8NXFCINZ60 ~ NEW YEAR EVENT 2009/10 ‘www youtube.com/watch?v=SI-Gili0p-g ~ IAS EVENT 2009 ‘www youtube.com/wateh?v=ob8qHol ViV8 IAS EVENT 2010 ‘www youtube.com/watehv=7xdL uuxj62e ~ IAS EVENT 2010 ‘www.youtube.com/wateh?v-MLkGbLNaag — IAS EVENT 2010 ‘wow. youtube.com/watch?v=Avh4EEhePPE — IAS EVENT 2011 ‘ww. youtube.com/wateh?v=7JYLQV9JVLM = IAS EVENT 2011 utube.comi/watch?v-H2uzwiinGW2M ~1AS EVENT 2013GaRy 8. SOTER Page 2 ‘Your taking and publication of copyrighted expression exceeded that necessary to disseminate the facts and infringed the copyright holder's interests in confidentiality and creative control over the first public appearance of the work. See Harper & Row Publishers, Inc. v. Nation Enterprises (1985) 471 U.S. $39, 540-41 [10S S.Ct. 2218, 2220, 85 L-Ed.2d 588] Thereby provide you with formal notice that CSI has never consented and does not consent to your possession, review, copying, dissemination, publication, uploading, downloading or any other use of the stolen documents, We demand that you return the stolen properties to me. CSI also demands that you promptly (1) notify us in writing of al of the CSI issues, documents, videos and recordings that ‘you received from Mr. Joseph; 2) notify us in writing of all of your receipt of al other issues, recordings and videos stolen or “taken” from any Church of Scientology; (3) take all reasonable actions to prevent anyone who has access to the materials from ‘examining copying, disseminating, distributing publishing, downloading or ‘making any other use of the stolen information on the documents; (4) produce to me immediately all copies of all materials listed in (1) ~ (3) above, including all hard copies, downloads, CD's, DVD's, flash drives or any other electronic media, In addition, if you have provided the stolen information to anyone else, CSI ‘demands that you provide me with the names of those persons and that you provide those persons with a copy of this letter and request those persons to comply with these written ‘demands. If you fail to comply with this request, CSI reserves the right to hold you, your agents and all other persons who received stolen information from you legally responsible for statutory damages and/or any actual damage or loss caused or contributedGary S, SoreR Page 3 toby the use or dissemination of the stolen information, Very truly yours, ‘THE LAW OFFICES OF GARY S, SOTER A PROFESSIONAL CORPORATION By as oe GAHYS, SOTER GssiesLaw oftes oF Gary S. SOTER A PROFESSIONAL CORPORATION 22287 MULHOLLAND HIGHWAY #169 ‘CALABASAS, CALIFORNIA 91302 (323) ¢60.1900 Fax (818) 530-4352 onvooreng SM aorERAN COM March 6, 2015 VIA EMAIL Ray B. Jeffrey 2631 Bulverde Road Suite 105 Bulverde, Texas 78163 jeffrey @simlawyers.com My assistant sent an e-mail to Karen De La Carriere concerning certain videos which had been stolen from the Church of Scientology. Ms. De La Carriere promptly responded that “[y}our Emails have been deleted without reading,” She claims that you represent her on an ongoing basis and that my assistant’s unopened email “is deliberate harassment.” ‘The lady doth protest too much, Her claims of harassment cannot be reconciled with her statement that the e-mail was deleted its contents. I don’t believe her. Ms. De La Carriere is already on In any event, please (1) let me know if you received the e-mail which we sent to Ms. De La Carriere; and (2) confirm in’writing that you do represent Ms. De La Carriere on an ongoing basis regardless of the nature or location of the dispute. If you do represent her, please respond to all issues set forth in my letter to her of February 25, 2015.Law tices OF Gany s.SoreR Page 2 We have similar issues to address with other persons who are suspected of conspiring with Ms, De La Carriere to steal Church property. Since she directed me to write to you, let us know whether you also represent Mr. Rathbun conceming stolen property issues. Please respond to this letter within three business days. Very truly yours, ‘THE LAW OFFICES OF GARY S. SOTER A PROFESSIONAL CORPORATIONJeffrey & Harris, PC 2551 Buhere Ra, Sie 105, Ray B. Jeffrey Boer, Tease 7168 ‘ao Cad ‘eo A005 Too Balog Soins (890) 1958 Fax Sartell (210) 7047282 tei tate March 11,2015, Gary 8. Soter Law Office of Gary S. Soter 22287 Mulholland Hwy, Suite 169 Calabasas, CA 91302 Re: Karen De La Carriere Dear Gary, Attached isthe email I directly sent you 0 years ago, entitled "Representation of Karen De La Carriere". Init, you were told that I represent Ms. De La Carriere, as follows: "If you have ‘any need to communicate with Ms. De La Carriere henceforth, I would appreciate it if you would contact me directly." Nevertheless, despite this prior notification and your knowledge that 1 ‘curently represent her, you have Seen fit to bypass me and threaten her ditectly Since you repeatedly demand answers to questions of interest to you, perhaps you will answer a single, simple question from me ~ is 2 California lawyer permitted to communicate rectly with an adverse party he knows to be represented by counsel? Despite your usual baseless accusations and threats against Ms. De La Carriere, 1 was ratified by one aspect of your latest correspondence ~ you acknowledge that she is lady! This is Quite an improvement over Scientology's most recent defamation campaign against Ms. De La Carriere in which it tries to porteay her as a prostitute in her youth As to Scientology's newest campaign to discredit Ms. De La Carriere, certainly, ‘Scientology's founder, L. Ron Hubbard, would not have personally invited Ms. De La Carriere t0 jin ts clergy ifshe truly was a person of such allegedly loose morals, nor would it have allowed, Heber Jentzsch, the President of the Church of Scientology. to many. let alone father a son with her. If there were any truth to Scienfology’s calumny against Ms. De La Carriere. the Church Would not have advanced her to important corporate positions and awarded her among its highest recognitions. The Office of Special Affairs has the uncanny ability to retroactively “discover” spectacular failings inthe most prominent former ScientologistsGary $. Soter Mareh 11, 2015 Page 2 Regarding your client's accusation du jour that Ms. De La Cartiere has stolen, conspired to steal and/or is violating Scientology's copyrights, thee is no legitimate evidence of same and your X's claims are false, The only thing Ms, De La Carrere is guilty of is exercising her First Amendment rights to comment on matters of public interest and her fae use of snippets of videos ‘which are widely available in various public forums. Ifyou do not believe that these are matters of public interest, you may want to tune into HBO later this month. Inthe future, please direct any communications intended for Ms. De La Carriere directly to Very iuly yours, RBIicatYougtiy Hi SurvivingScientology: Due to a copyright takedovin notice that we received, we had to take down the following videos from YouTube: Video title: Scientology Dictator David Miscavige ~Garbage In, Garbage out Video url: hitp://waw youtube com/watch?v=7xdLuuxi62c ‘Takedown issued by: Church of Scientology Intemational Video title: Scientology Inc ~ultimate truth given out every 10 seconds, | am Impacted | Video urt: http://w, youtube, com/watch?v=ob8a-ot VIVE ‘Takedown issued by: Church of Scientology Intemational Video title: Scientology Inc has promised “Super Power" since 1978 ! Also Fundraising Funnies Video url itp J/waw youtube. corn/watch?v=Avh4E EhePPE ‘Takedown issued by: Church of Scientology Intemational Video title: Scientology Inc sold sptual"ibeation” to OT Vill Gek Isene. Geir speaks Video url Takedown Issued by: Church of Seontlogy International Video title: Scientology Inc's Office of Special Affairs ~~ Execution arm for David Miscavige. 3/6 ‘Video url hitp J/waw youtube com/watch?v=SJ-GiJi0p-9 ‘Takedown issued by. Church of Scientology Intemational ‘This means thet your video can no longer be played on YouTube, and yeu may have lost access to some features of YouTube You received a copyright strike ‘You now have 1 copyright strike. Getting muitiple copyright stikes can lead to the termination of your account and the removal of all your videos. To avcid that from happening, please don't upload videos that contain copyrighted cortent that you aren't allowed to use. Why this can happen ‘+ One or more of your videos contained copyrighted conten. ‘+ Copyright owners can choose to take down videos that contain their content. What to do next ‘+ If you believe youre not at fault, you can try to appeal this takedown by ‘submitting a counter notification, Keep in mind that there may be severe legal ‘consequences for submitting a counter notification with false Information,Youn Hi SurvivingScientology: Due to a copyright takedown notice that we received, we had to take down your video: from YouTube: Video title: Scientology Inc Sea Org Member of 23+years gets the HIV virus in employ of Freewinds 2/2 Video urt: http://w, youtube, com/watch?v-s0S-VOBXdg ‘Takedown issued by: Church of Scientology Intemational This means that your video can no longer be played on YouTube, and you may have lost access to some foatures of YouTubo. You received a copyright ‘You now have 2 copyright strikes. Getting multiple copyright strikes can lead to the termination of your account and the removal of all your videos. To avold thet from happening, please don’t upload videos that contain copyrighted content that you aren't llowed to use. Why this can happen + One or more of your videos contained copyrighted content. + Copyright overs can choose to teke dovin videos that contain their content. What to do next + If you believe youre not at fault, you can try to appeal this takedown by submitting a counter notification. Keep in rind that there may be severe legel consequences for submitting a counter notification with false information. + You can also contact the party that removed your video and ask them to retract their takedown, Help center Email options €2015 YouTube, LLC 901 Chemry Ave, San Bruno, CA 94066Youiip Dear SurivingScientology, ‘Thankyou for your counter notfication. thas been forviarded to the party that sentthe takedown notification. Ifwe receive no response, your material will be restored in 10 to 14 business days from today. Please understand that submitting additional counter notifications for this URL will not accelerate your videoss reinstatement. -The YouTube Team Counter-Notfication as follows: ‘Videos included in counter nomncation: http Juww.youtube.com/watch?y=8J-GUi00-g hitov/wu youtube. comwatch?v=608-1VOBXdq hte: ww youtube comwatch?v=O8NXFCINZ60 'v=Avn4EEhePPE htipy/ww youtube comwatch?v=ob8qHo1ViV8 hitipy/vww youtube comwatch?v=7xdLuuxi62c inipyww youtube. comwatcn?v=MILKGDLNaa Ta hip www youtube corvwatch?v=7JYLQV9JVLM httpyww youtube. comwatch?>v=H2uzwHnGW2M Display name of ualoader: SurvivinaScientology Please stop trying to interfere with my rights of ree speach and commentary on newsworthy events | swear, under penalty of perjury, that lhave a good faith belief the material was removed ‘due to a mistake or misidantiication of the materal to be removed or cisabled. I consentto the jurisdiction of the Federal Distict Courtfor the district in which my address is located, orifmy addressis outside of the United States, the judicial district in wich YouTube ls located, and wil accept service of process rom the clamant. Karen dela Carriere Help center» Email options Report spam