Declaration of Michael Rinder¹

Pursuant to 28 U.S. C. § 1746, MICHAEL RINDER deposes and states:

1. I was a member of the Board of Directors of the Church of Scientology International from 1983 until 2007, when I terminated my relationship with the Church of Scientology and all related entities.

2. I was raised as a Scientologist from the age of 6 and, as such, am well versed on the policies and procedures of the Church of Scientology.

3. I have read the Defendants’ Response to Court Order Regarding Arbitration Proceedings which alleges to describe Scientology “arbitration procedures.” It constitutes a fraudulent misrepresentation of non-existent “arbitration” procedures

4. During the course of my employment as head of Church’s worldwide legal matters for more than 20 years, I became aware of attempts made by persons to get their money back from the Church. Every such attempt was reported to me on a weekly basis.

5. During the course of my employment with the Church, I was responsible for creating the Enrollment Agreement and “arbitration” clause, and I was also responsible for providing the rules for “arbitration.” No procedures describing the “arbitration” process, beyond selection of the arbitral panel, were or have ever been delineated. Names and duties, such as chairman and secretary, were never assigned or contemplated. It simply was not the intent of the Church that the “arbitration” process amount to anything beyond a statement on paper.

6. Since the inclusion of the “arbitration” clause in the Enrollment Agreement, I am not aware of a single instance where anyone has participated in “arbitration” in connection with a return of their money.

7. Defendants have intentionally comingled the Committee of Evidence and the “arbitration” process, and have understandably failed to attach to their Response, the relevant pages of the book they refer to as their authority, Introduction to Scientology Ethics, which contains the procedures and rules governing a Committee of Evidence. To have done so would have resulted in the blatant exposure of the selective quotations, provided by the Defendants, which have been used to paint a VERY misleading and fraudulent picture of the non-existent “arbitration” proceeding.

8. The purpose, function and procedural substance applicable to the Committee of Evidence, were not and are not, intended to apply to “arbitration.”

a. It is Church doctrine and practice that a Committee of Evidence is convened when it is suspected or alleged that a given person has committed a wrong (a “Crime” or ”High Crime” in Scientology parlance).

b. It is Church doctrine and practice that a Committee of Evidence functions as a fact-finding jury, in no way similar to an arbitration panel.

c. It is Church doctrine and practice that a Committee of Evidence consists of appointed members, rather than party-selected arbiters.

d. It is Church doctrine and practice that a Committee of Evidence is not authorized to preside over matters relating to return of funds.

e. Declarant Mansell noted acq1rately the separation between the Committee of Evidence and the “arbitration” process.

f. As written into the Enrollment Agreement, the guise of
“arbitration” was intended to apply after a person exhausted the review by the IJC.

9. I am familiar with the pages of the Introduction to Scientology Ethics as attached hereto. Its contents are accurate and constitute true and complete copies of the applicable pages of the book.

I declare under the penalty of perjury that the foregoing is true and correct.

Executed this 6th day of November, 2013 in Palm Harbor, Florida.

Michael Rinder

Notes