c/o 12400 Ventura Blvd. #137
Studio City, California (18 U.S.C. 1342)
In propria persona [NOT PRO SE]
In the superior court for Los Angeles county, California
FOOTNOTE 1: Concurrent with and equivalent to the district court as created in the Constitution of the State of California of 1849, and the seventeenth judicial dietrict, see Stats 1872, ch. CXIV, p. 116
Stephen Mitchell; Lisa Jan Precious; Kathleen
DAVID MISCAVIGE, a person, in the capacity
as Chairman of the Board of the Religious Technology Center and Inspector
General of the Church of Scientology
MIKE RINDER, a person, in the capacity as head of the Office of Special Affairs International
JOHN/JANE DOE #1, a person, in the capacity as head of the L. Ron Hubbard Library
JOHN/JANE DOE, #2-99
Case No. BC175367
Verified Statement of Demand for Damages of
in support of the Verified Complaint for Libel
The libelous document entitled "PUBLIC WARNING, SUBJECT: Squirrel tax avoidance schemes", complained of in the abovenumbered case has created damages by the misstatement of facts.
1. This libelous document was circulated through the United States Postal Service to an untold number of Scientologists, and perhaps others as well.
2. The scope of influence enjoyed by the Church of Scientology and its related organizations (Religious Technology Center, Office of Special Affairs International, et al.), whether in Hollywood, the business world or the Cabinet of the White House itself, can be seen and measured by the content of the attached open letter (see Exhibit SM1) the signatories to which, though not Scientologists, were sufficiently influenced by the campaign of Scientologists to convince them to sign this public statement which appeared, among other places, in the Los Angeles Times newspaper. No less a personage than Madeleine Allbright, the U.S. Secretary of State, carried the message contained in the open letter to the German government as part of a diplomatic visit on behalf of the United States Government.
3. Due in great part to the credibility the church has established for itself in such circles, the damages that the libelous document has created can be summarized as follows:
3a. Lost revenues from Scientologists who had formerly been conducting business with this Plaintiff and/or his associates. Some have submitted "disconnect" letters to this Plaintiff_one specifically stating that Office of Special Affairs International told him to disconnect. (documentation to be shown at time of trial) Certain others have simply dropped away without comment;
3b. Lost revenues from the diminished capacity to sell a Stephen Mitchell property (e.g.: story idea, screenplay, completed film or TV show/series) owing to the allegations in the libelous document that this Plaintiff is a criminal, a tax protester and is insane, ideas which the libelous document conveys to the public in no uncertain terms)
3c. Lost revenues from the diminished capacity to establish marketing agreements, licensing agreements, publishing agreements, cross-promotional agreements and franchising relating to television shows and/or movies created by Stephen Mitchell with publicly-held companies around the globe whose officers cannot, or will not, risk even the appearance of impropriety when committing their companies to such financial arrangements;
3d. Lost revenues from the diminished capacity to attract well-known directors, screenwriters and actors to the production of movies and/or television shows created by or produced by Stephen Mitchell, for fear that they would tarnish their own reputations with the public, or for fear of offending such major Scientologist stars as Tom Cruise, Nicole Kidman or John Travolta, whose influence within the Hollywood community is considerable.
4. These damages are hereby construed as willful and malicious, considering that the legality of Plaintiff Stephen Mitchell's status_the very same status as shared by Don Rogers, formerly of the California legislature, which body, after review, gave Senator Rogers a "clean bill of health"_has been made clear to the church in two Committees of Evidence in the Los Angeles area (tape and transcriptions to be shown at time of trial) and in numerous written correspondences with officials of the church including, but not limited to, David Miscavige (Religious Technology Center) and Kurt Weiland (Office of Special Affairs International).
5. This Plaintiff believes and avers that the malicious intent of the allegations made in the libelous document, are at least in part, a retaliation for reports written by this Plaintiff enumerating and disclosing misconduct and potentially criminal actions on the part of highly placed officials in the church. (documentation to be shown at time of trial).
6. The malicious intent of the libelous document is further established by the fact that on 6/17/96 church employee Matthew Veenker admitted in writing (documentation to be shown at time of trial) to having intercepted a report sent by this Plaintiff through the United States Post Office to another church employee who had convened a Committee of Evidence (an ethics panel for handling internal church justice actions) in Nashville, Tennessee. This action to suppress this Plaintiff's communication was taken by Veenker to keep damaging information regarding David Miscavige and others in church management out of said Committee's view.
7. Additional evidence of the malicious intent of the libelous document is established [by] the fact that prior to this Plaintiff's written reports concerning wrongdoing by the Church's upper management, church issues on the subject of Stephen Mitchell were laudatory and spoke of long-standing and continuing contribution to the well-being of the church, its expansion and popularization (see Exhibit B).
8. The allegations in the libelous document have been used to discredit Stephen Mitchell and to be a distraction from the truth of the content of said reports.
9. Another Scientologist, Michael Baybak, has previously established that libel damages have a value of $60 million in a libel suit against a major national publication. This is confirmed by a Scientology press release by Teisa Goodman headlined as "Multi-million Suit Against TIME Magazine to go to Trial ".
10. Based on all the foregoing, Stephen
Mitchell hereby demands that damages be paid in
an amount to be no less than $60,000,000.00.
I, Stephen Mitchell, hereby swear under penalty of perjury, under the law of the Land in California, one of the United States of America, that paragraphs 1 through 10 hereinabove are true and correct and so done in good faith to the best of our knowledge and belief.
Subscribed and sworn this twenty-ninth
day of the seventh month, in the year A.D. nineteen
hundred ninety seven.
[L.S.] (SIGNATURE: STEPHEN MITCHELL) seal