Electronically FILED by Superior Court of California, County of Los Angeles on 12/10/2020 01:15 PM Sherri R.

Carter, Executive Officer/Clerk of Court, by M. Panganiban,Deputy Clerk

1
Robert W. Thompson, Esq. (SBN: 250038)
2 Casey A. Gee, Esq. (SBN: 284830)
THOMPSON LAW OFFICES, P.C.
3 700 Airport Blvd., Suite 160
Burlingame, CA 94010
4
Tel: (650) 513-6111 / Fax: (650) 513-6071
5
Brian D. Kent, Esq. (Admitted Pro Hac Vice)
6 Gaetano D’Andrea, Esq. (Admitted Pro Hac Vice)
7 M. Stewart Ryan, Esq. (Admitted Pro Hac Vice)
LAFFEY, BUCCI & KENT, LLP
8 1435 Walnut Street, Suite 700
Philadelphia, PA 19102
9 Tel: (215) 399-9255 / Fax: (215) 241-8700
10
Attorneys for Plaintiffs
11
12 SUPERIOR COURT OF THE STATE OF CALIFORNIA

13 FOR THE COUNTY OF LOS ANGELES - UNLIMITED CIVIL JURISDICTION

14
15 CHRISSIE CARNELL BIXLER; CEDRIC Case No.: 19STCV29458
16 BIXLER-ZAVALA; JANE DOE #1; MARIE
BOBETTE RIALES; and JANE DOE #2; Assigned to Hon. Steven J. Kleifield, Dept. 57
17
Plaintiffs, PROOF OF SERVICE OF SUMMONS ON
18 DAVID MISCAVIGE; DECLARATION OF
19 vs. DUE DILIGENCE OF CARLOS
FERNANDEZ
20 CHURCH OF SCIENTOLOGY INTERNATIONAL;
RELIGIOUS TECHNOLOGY CENTER; CHURCH
21
OF SCIENTOLOGY CELEBRITY CENTRE Action Filed: August 22, 2019
22 INTERNATIONAL; DAVID MISCAVIGE;
DANIEL MASTERSON; and DOES 1 – 25;
23
Defendants.
24
25
26
27
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___________________________________________________________________________________
PROOF OF SERVICE OF SUMMONS; DECLARATION OF DUE DILIGENCE
 DECLARATION OF CARLOS FERNANDEZ

STATE OF CALIFORNIA
COUNTY OF LOS ANGELES

I, Carlos Fernandez, do hereby declare that I am a private investigator in the

State of California. I am licensed under California P.I. #17676.

I have been employed by Intellectual Property Enforcement Company, Inc.

(IPEC, Inc.), for the past 30 years. I have over ten thousand five hundred hours of
formal, on-the-job training, and experience.

I am continuously hired by law firms to investigate intellectual property,

commercial fraud, family law, property security, person security, background, process
service, criminal investigation, civil investigation and personal injury cases. Many of
these investigations include surveillance, undercover work, process serving and the
locating of individuals including that of witnesses. I have worked approximately 200
cases in the past year involving such cases.

On November 17, 2020, I was hired by Thompson Law Offices, P.C. who is
located at 700 Airport Boulevard, Suite 160, Burlingame, CA 94010 to serve the
following documents to David Miscavige:

1. Summons;
2. Civil Cover Sheet with Civil Case Cover Sheet Addendum and Statement of
Location;
3. Complaint for Damages;
4. Notice of Jury Fee Deposit;
5. Notice of Case Management Conference;
6. Los Angeles County Superior Court Standing Order Re: Personal Injury
Procedures, Central District;
7. Los Angeles County Superior Court First Amended General Order;
8. Los Angeles County Superior Court Alternative Dispute Resolution Information
 Package;
9. Los Angeles County Superior Court First Amended Standing Order Re: Final
Status Conference, Personal Injury (“PI”) Courts;
10. First Amended Complaint; and
11. 11/6/20 Minute Order.

On November 21, 2020, I traveled to the Church of Scientology International,

located at 6331 Hollywood Boulevard, Los Angeles, CA 90028, where David Miscavige
resides according to public records, and to the Religious Technology Center
International, located at 1710 Ivar Avenue, Los Angeles, CA 90028, where David
Miscavige is employed as the Chairman of the Board. Both addresses belong to the
same building.

I arrived at the Church of Scientology International address at approximately 9:50

AM. The main entrance for 6331 Hollywood Boulevard is located to the right of the
building and the address of “6331” is depicted at the right bottom of the building. There
is a pin pad next to the door and there is also a yellow sign that says, “Attention, please
do not enter if you are ill or have been around others who are ill. Get the Receptionist’s
attention so that you may be screened with a no-contact thermometer before entering
the premises.” The doors themselves are glass but have a white curtain that covers
them so no one can see inside.

As I knocked on the door, a Caucasian male opened the door. The Caucasian
male is best described as being in his mid 40’s approximately 6’1 or taller and had
graying hair. I asked him if David Miscavige was in. The Caucasian male stated that he
was not in. I stated that I need to deliver a package to him, asked how I could do this
and if I could at this location. The male stated that I could not and ended the
conversation closing the door.

I then walked around the corner to the Religious Technology Center International
address of 1710 Ivar Avenue, Los Angeles, CA 90028 in attempt to serve David
Miscavige at his place of employment. I arrived at the location at approximately 9:54
AM. The address of “1710” is depicted above the brown entrance door. Next to the
entrance door, there is a telephone box. There is a driveway with a black security gate
to the left of the building.

There was a Caucasian male security guard posted up in front of the door. The
security guard was wearing a black uniform with gold lettering on the uniform. The
security guard is best described as being 6’1” with light brown hair and a heavy foreign
accent. I asked him for David Miscavige. He said he was not here. I asked if he was
inside and told him that I had a package for David Miscavige. He said he was not in and
that I needed to leave. I thanked him for his time and departed from the location.

On November 25, 2020, I returned to the 6331 Hollywood Boulevard address in

attempt to serve David Miscavige at his home. I arrived at approximately 12:40 PM.

As I arrived, two Caucasian females were exiting the location wearing dark blue
pants. One wore a dark blue sweater while the other wore a dark blue blazer jacket.
When I arrived at the door, I knocked on the door and a Caucasian male opened the
door. This Caucasian male is best described as being in his late 20’s approximately 5’8”
and had black hair. I asked him if David Miscavige was in. The Caucasian male stated
that he was not in. I stated that I need to deliver a package to him, asked how I could do
this and if I could at this location. The Caucasian male stated that I could not and ended
the conversation closing the door.

I then walked around the corner to 1710 Ivar Avenue, Los Angeles, CA 90028 in
attempt to serve David Miscavige at his place of employment. As I was walking up to
the door, I saw as two males wearing all black loading packages into the trunk of a gray
four door sedan. The car was identified as being a Ford vehicle with California license
plates 7LON646.

I arrived at the location at approximately 9:54 AM. The address of “1710” is

depicted above the brown entrance door. As I knocked on the door, an Asian male
opened the door. He was the same Asian male that was observed loading the car trunk.
The Asian male is best described as being in his mid 20’s approximately 5’7” and had
black hair. I asked him if David Miscavige was in. The Asian male stated that he was
not in. I stated that I need to deliver a package to him, asked how I could do this and if I
could at this location. The Asian male asked me if I had an invoice. I stated that I did
not have an invoice and that I would check on this. At this time, the conversation was
ended and the Asian male closed the door.

On December 2, 2020, Investigator Yvette Moreno and I returned/traveled to the

building with the 6331 Hollywood Boulevard and 1710 Ivar Avenue addresses. We
arrived together at 3:20 PM in attempt to serve David Miscavige. We separated at the
corner of Ivar and Hollywood. I went to attempt to serve at 1710 Ivar Avenue while
Investigator Moreno attempted service at the 6331 Hollywood Boulevard address.

Investigator Moreno knocked on the 6331 Hollywood Boulevard address and a

Caucasian male answered the door. The male is best described as being in his late 40’s
approximately 5’9”, 160 lbs., light brown hair and blue eyes.

At this time, Investigator Moreno asked the male if David Miscavige was in. The
Caucasian male stated that he was not in and asked how he could help her. Investigator
Moreno proceeded to give the service packet to the Caucasian male, who then threw up
his hands in the air and stated that he could not accept service. Investigator Moreno told
him that it was okay and she proceeded to put the papers on the floor on the inside of
the building in front of the Caucasian male.

At this time the Caucasian male started to kick at the paperwork. Investigator
Moreno advised him that it was probably not a good idea for him to kick out the
paperwork into the street and public. The service packet was still inside the building
when Investigator Moreno departed the location.

When I arrived at 1710 Ivar Avenue, I rang the doorbell. I observed the entrance
door slightly open. I entered the location. Once inside, I observed a mailroom with
packages throughout. Inside towards the rear right, there were two Caucasians males
working. I note that when they did speak to me later, they spoke in a very heavy foreign
accent. One of the males is best described as being in his early to mid 40’s,
approximately 5’9”, 185 lbs., black hair, brown eyes with corrective eyewear. The
second male is best described as being in his mid to late 30’s, approximately 5’9”, 175
lbs., black hair and brown eyes.
 As I called out to them, they turned to me and I asked if David Miscavige was in.
They both turned to me, and I am not sure which one spoke, but between the both of
them, they told me that I could not be there cmd that I needed to go outside and ring the
doorbell. I told him that I did ring the doorbe II and that I had a package for David
Miscavige. At this point, they started to walk towards me telling me to get out. I told
them that I was serving them with paperwork: and proceeded to place the service packet
on a shelf near them as they came towards me. Where I placed the service paperwork
there was a label depicting, "Mail Packs". I then walked out and departed the location
leaving the set of papers inside the 171O Ivar Avenue location.

On the same day, the service packets were mailed out to both locations
separately via the United States Postal Service (USPS). The packets were addressee! to
David Miscavige at 1710 Ivar Avenue, Los Angeles, CA 90028 and 6331 Hollywood
Boulevard, Los Angeles, CA 90028. The USPS Express Next Day tracking numbers for
the service packets are EJ567165141 US and EJ567165138US. USPS.com states the
service packet with tracking number EJ567165141US was delivered to 1710 Ivar
Avenue at 10:42 AM on December 3, 2020. USPS.com states the service packet with
tracking number EJ567165138US was delivered to 6331 Hollywood Boulevard at 11 :59
AM on December 3, 2020.

I do herebydeclareunder penaltyof perjurythat the foregoingis true and correct

to the best of my knowledge.

Dated this /0 day of ~,; ..k,.,2020 in Los Angeles County.

 1
Robert W. Thompson, Esq. (SBN: 250038)
2 Casey A. Gee, Esq. (SBN: 284830)
THOMPSON LAW OFFICES, P.C.
3 700 Airport Blvd., Suite 160
Burlingame, CA 94010
4
Tel: (650) 513-6111 / Fax: (650) 513-6071
5
Brian D. Kent, Esq. (Admitted Pro Hac Vice)
6 Gaetano D’Andrea, Esq. (Admitted Pro Hac Vice)
7 M. Stewart Ryan, Esq. (Admitted Pro Hac Vice)
LAFFEY, BUCCI & KENT, LLP
8 1435 Walnut Street, Suite 700
Philadelphia, PA 19102
9 Tel: (215) 399-9255 / Fax: (215) 241-8700
10
Attorneys for Plaintiffs
11
12 SUPERIOR COURT OF THE STATE OF CALIFORNIA

13 FOR THE COUNTY OF LOS ANGELES - UNLIMITED CIVIL JURISDICTION

14
15 CHRISSIE CARNELL BIXLER; CEDRIC Case No.: 19STCV29458
16 BIXLER-ZAVALA; JANE DOE #1; MARIE
BOBETTE RIALES; and JANE DOE #2; Assigned to Hon. Steven J. Kleifield, Dept. 57
17
Plaintiffs, DECLARATION OF SERVICE
18
19 vs.
Action Filed: August 22, 2019
20 CHURCH OF SCIENTOLOGY INTERNATIONAL;
RELIGIOUS TECHNOLOGY CENTER; CHURCH
21
OF SCIENTOLOGY CELEBRITY CENTRE
22 INTERNATIONAL; DAVID MISCAVIGE;
DANIEL MASTERSON; and DOES 1 – 25;
23
Defendants.
24
25
26
27
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___________________________________________________________________________________
DECLARATION OF SERVICE
 1 DECLARATION OF SERVICE
2 Chrissie Carnel Bixler, et al. v. Church of Scientology International, et al.
Los Angeles County Superior Court Case No.: 19STCV29458
3
4 I am employed in the County of San Mateo, State of California. I am over the age of 18 and not a
party to the within action. My business address is 700 Airport Blvd., Suite 160, Burlingame, California
5 94010.

6 On December 10, 2020, I served the within document(s) described as:

7 Plaintiffs’ Proof of Service of Summons on David Miscavige; Declaration of Due Diligence of

Carlos Fernandez
8
on the interested parties in this action as stated below:
9
SEE ATTACHED SERVICE LIST
10
(MAIL) I enclosed the documents in sealed envelope(s) addressed above. I am readily familiar
11 □ with this firm's practice of collection and processing correspondence for mailing. Under that
12 practice it would be deposited with the U.S. postal service on that same day with postage thereon
fully prepaid at Burlingame, California, in the ordinary course of business. I am aware that on
13 motion of party served, service is presumed invalid if postal cancellation date or postage meter date
is more than 1 day after date of deposit for mailing in affidavit.
14
(OVERNIGHT DELIVERY) I enclosed the documents in sealed envelope(s) addressed above
15
□ provided by an overnight delivery carrier. I placed the envelope(s) for collection and overnight
delivery at an office or a regularly utilized drop box of the overnight delivery carrier.
16
(FACSIMILE) I caused such document(s) to be delivered by facsimile pursuant to court order or
17 □ agreement of the parties. The facsimile machine I used complied with Rule 2.301(3) and no error
was reported by the machine.
18
(ELECTRONIC MEANS) I caused such document(s) to be delivered by electronic service pursuant
19 to court order or agreement of the parties.
20 (PERSONAL DELIVERY) I caused such document(s) to be personally served on the person listed
□ above.
21
22 Executed on December 10, 2020, at Burlingame, California. I declare under penalty of perjury
under the laws of the State of California that the foregoing is true and correct.
23
24 Alicia Young /s/
(Type or print name) (Signature)
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___________________________________________________________________________________
DECLARATION OF SERVICE
 1 SERVICE LIST
2 Plaintiffs’ Counsel Defendants’ Counsel
3
Robert W. Thompson, Esq. William H. Forman, Esq.
4 Casey A. Gee, Esq. David C. Scheper, Esq.
Thompson Law Offices, P.C. Margaret E. Dayton, Esq.
5 700 Airport Blvd., Suite 160 Scheper Kim & Harris LLP
Burlingame, CA 94010 800 West Sixth Street, 18th Floor
6
Email: bobby@tlopc.com Los Angeles, California 90017-2701
7 Email: casey@tlopc.com Email: wforman@scheperkim.com
Email: alicia@tlopc.com Email: dscheper@scheperkim.com
8
Email: pdayton@scheperkim.com
Brian D. Kent, Esq. (Admitted Pro Hac Vice) Attorneys for Defendants Church of Scientology
9
Gaetano D’Andrea, Esq. (Admitted Pro Hac Vice) International and Celebrity Centre International
10 M. Stewart Ryan, Esq. (Admitted Pro Hac Vice)
Laffey, Bucci, & Kent, LLP Robert W. Mangels, Esq.
11 1435 Walnut Street, Suite 700 Matthew D. Hinks, Esq.
12 Philadelphia, PA 19102 Jeffer, Mangels, Butler & Mitchell, LLP
Email: bkent@lbk-law.com 1900 Avenue of the Stars, 7th Floor
13 Email: gdandrea@laffeybuccikent.com Los Angeles, California 90067
Email: sryan@laffeybuccikent.com Email: rmangels@jmbm.com
14 Email: vzeoli@laffeybuccikent.com Email: mhinks@jmbm.com
Email: jkerr@laffeybuccikent.com Attorneys for Defendant Religious Technology
15 Center
16 Jeffrey P. Fritz, Esq. (Admitted Pro Hac Vice)
Jeffrey K. Riffer, Esq.
SOLOFF & ZERVANOS, P.C. Elkins Kalt Weintraub Reuben Gartside, LLP
17 1525 Locust Street, 8th Floor 10345 W. Olympic Blvd.
18 Philadelphia, PA 19102 Los Angeles, California 90064
Email: jfritz@lawsz.com Email: jriffer@elkinskalt.com
19 Email: lgoodfellow@lawsz.com Attorney for Defendant David Miscavige
Email: jgilbert@lawsz.com
20 Andrew B. Brettler
Marci Hamilton, Esq. (Admitted Pro Hac Vice) Lavely & Singer, P.C.
21
University of Pennsylvania 2049 Century Park E., Suite 2400
22 Fox-Fels Building Los Angeles, California 90067
3814 Walnut Street Email: abrettler@lavelysinger.com
23 Attorney for Defendant Daniel Masterson
Philadelphia, PA 19104
24 Email: hamilton.marci@gmail.com

25 Graham E. Berry (SBN: 128503)

26 Law Office of Graham E. Berry
3384 McLaughlin Avenue
27 Los Angeles, CA 90066
Email: grahamberryesq@gmail.com
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DECLARATION OF SERVICE