Leah Remini spells out Scientology’s abuses in stunning new court declaration

We’re still going through the more than 700 pages of new court documents that Leah Remini and her legal team submitted to the court Friday in response to Scientology’s attempt to gut her lawsuit against her former church.

Yesterday, we brought you the new 12-page sworn statement by Mike Rinder that exposed Scientology’s retaliation policy of “Fair Game.”

Leah’s own declaration is even longer at 33 pages, and contains some new details about how Scientology’s constant attacks have affected her life. We knew you’d want to see it in its entirety.

(Please note that some of the things Leah is referencing here are responses to specific allegations made by Scientology in its motion to strike, and so they may lack some larger context. Also, if the post is too long for the email you receive this on, please see the entire post at tonyortega.substack.com)

 
COMES NOW, Plaintiff Leah Remini, who hereby attests as follows:

1. I am the Plaintiff in the above-captioned action. I filed my lawsuit, alleging Civil Harassment, Stalking, Infliction of Emotional Distress, Tortious Interference with Contractual Relationship, Intentional Interference with Prospective Economic Advantage, Defamation and Defamation Per Se, Defamation by Implication, False Light, and Declaratory Judgment on August 2, 2023. A First Amended Complaint was filed on August 29, 2023.

2. I am a former Scientologist of over 35 years.

3. I was deemed a Suppressive Person (an enemy, to be silenced by Scientology’s
Office of Special Affairs and civilian Scientologists alike) and declared Fair Game by Scientology in 2013, when I publicly departed Scientology, a Suppressive Act (a Scientology High Crime) as laid out by Scientology directives.

4. Since that time, Defendants have undertaken a campaign to silence, ruin and destroy my life, career, reputation, and livelihood as laid out by their directives.

5. For the past ten years, I have been stalked, surveilled, harassed, threatened, intimidated, and, moreover, have been the victim of malicious and false rumors via hundreds of Scientology controlled and coordinated social media and websites including but not limited to leahreminithefacts.org, leahreminiaftermath.com, freedommag.org, and standleague.org. Defendants have also incessantly harassed, threatened, intimidated, and embarrassed my family members, friends, colleagues, former colleagues, prospective colleagues, and business associates, causing me to lose personal relationships, business contracts, and other business opportunities.

6. Defendants have caused me significant and ongoing economic harm.

7. Despite spending nearly ten years of my life under constant threat and assault by Defendants as a result of my public departure from Scientology, I have worked tirelessly to advocate for current Scientologists, former members of Scientology, and non-Scientologists who have bravely spoken out against Scientology or supported Scientology survivors and whistleblowers.

My Experience in Scientology

8. Beginning at age eight, I effectively lost my mother as a parent when my mother joined Scientology. My mother often left her two daughters alone so that she could devote herself to Scientology. At the age of 13, my sister and I were made to leave the only home we ever knew and were forced to join the Sea Org by our mother. As part of joining, we were forced to sign billion-year contracts. I was deprived of a formal education or a normal childhood and made to perform manual labor and spend hours learning the teachings of L. Ron Hubbard. I was taught as a child to believe that my personal sacrifice would save the planet. Years of brainwashing and conditioning put me in a position where Scientology was the only reality for me. As with most Scientologists, Scientology was my primary caretaker. I was a member of Scientology for over 35 years.

9. During the period of time when I was a Scientologist, I was forced to pay for and undergo thousands of hours of Scientology training, at substantial cost to me, to move up what is known as Scientology’s Bridge to Total Freedom. These training sessions took many forms of conditioning and abuse which involved verbally, physically, and sexually abusive practices. One training technique known as “bull baiting” placed me, a young girl, with an older male Scientologist who was required to find my “buttons” (vulnerabilities that would bother me), screamed expletives at me, made sexually suggestive remarks to me, and verbally abused me for hours in an effort to condition me to not react to abuse. These training routines (“TRs”) which are required for all Scientologists, are part of the procedures to condition Scientologists to accept abuse and inflict abuse without hesitation. These TRs rob minor children of their natural protective instincts and open them up to sexual, physical, and emotional abuse. I was also forced to undergo Scientology auditing that coerced, suggested, and demanded that I admit to heinous acts in previous lives including sex acts as a child. I was taught as a Scientology auditor to demand these “transgressions” from those to whom I was administering Scientology auditing to, no matter the age of the recipient.

10. I estimate that I spent over $5 million over the course of my time as a Scientologist. These funds were spent on my so-called spiritual enlightenment and those of my family members and friends. Approximately half of my funding was for services that members are forced to purchase in advance for their “spiritual enlightenment.” As with other businesses, one does not receive Scientology major services without pre-paying. Like any member of Scientology, I was forced to “donate” to the International Association of Scientologists (“IAS”), for which there is no exchange of Scientology services. I understand the IAS to be David Miscavige’s war chest. I was unable to obtain repayment of monies I had on my and my family’s Scientology accounts. This allows Scientology to amass funds which former members cannot get back for pre-paid services that they do not plan on using. Scientologists who ask for their money back are committing a Scientology High Crime and breaking Scientology law. Once a former member demands their unused monies on their account, they are no longer allowed to contact anyone within the organization (Sea Org members or civilian Scientologists), even one’s own children and parents. Scientology will instruct any Scientologists in good standing that the former member is now a “Refund Case” and an enemy of Scientology. The only person an enemy of Scientology can contact is Mike Ellis, Scientology’s “International Justice Chief. This system creates a catch-22 where Scientology always wins.

11. While I was a Scientologist, giving millions of dollars to Scientology, serving as a public face for Scientology, recruiting people individually to join Scientology, helping to move Scientologists on their bridge, and donating to Scientology front groups at the behest of Scientology, I frequently was held up as an example of a model Scientologist and praised repeatedly for my contributions. I was awarded commendations by David Miscavige, Tom Cruise, and by the very people who later attacked me in Scientology-produced videos, despite repeatedly having been asked to appear in Scientology videos myself. As soon as I left and spoke out against Scientology, I was labeled by the organization I supported financially as an untrustworthy apostate, as has been the case for staff members, Sea Org members and other Scientologists who have left Scientology or who have spoken out, and for non-Scientologists who have made a joke about Scientology, reported crimes against, or advocated for victims of Scientology.

12. Scientology’s campaign to destroy me began in 2006, seven years before I publicly left Scientology in the summer of 2013. This background is described solely to provide context for Scientology’s attacks on me after I publicly left Scientology.

13. In 2006, my husband and I attended the wedding of Tom Cruise and Katie Holmes in Italy. Cruise, David Miscavige’s best friend, is essentially second in command in Scientology. It is a High Crime in Scientology to criticize him in any way. In 2004, David Miscavige told an audience of Scientologists at a gala in England that Cruise was “the most dedicated Scientologist I know.”

14. The Cruise-Holmes wedding was billed within Scientology as “The Wedding of the Century.” Because of Mr. Cruise’s status within Scientology and how important this event was, I was shocked to discover that David Miscavige’s wife, Michele (“Shelly”) Miscavige, was nowhere to be found. Shelly Miscavige held the title of “Assistant to Chairman of the Board (COB)” and her job was to constantly record everything he said so that a team of secretaries could later transcribe his words and orders for dissemination throughout Scientology.

15. When I asked a group of Scientology executives and Tom Cruise’s personal handlers, Tom Davis, Jessica Feshbach, and Javier Ruiz, “Where is Shelly?,” I was immediately admonished by the group, despite the fact that Ms. Miscavige and I were good friends.

16. I witnessed other behavior at the wedding that set off red flags for me, including unethical contacts between various Scientology executives and others at the wedding which I understood to be forbidden by Scientology teachings.

17. While in Italy, I called my Scientology assistant, Melinda Brownstone, and asked her to type up a series of internal reports that I was taught to write, known as Knowledge Reports (“KRs”), sharing my concerns about the behavior I had witnessed and expressing my concerns about Ms. Miscavige’s health and safety.

18. I dictated these reports over the phone to Brownstone, who wrote and submitted these reports because, from a young age, I had been brainwashed into believing that by filing reports like this, I was helping Scientology and saving my religion.

19. When I returned to Los Angeles, I was ordered to go to Clearwater, Florida, to the Flag Land Base building, also known as “FLAG.” FLAG is considered the spiritual headquarters of Scientology, where Scientologists receive top-level services that cannot be obtained anywhere else.

20. I was told that before I could receive the services I had planned on getting while there, I would undergo a quick “ethics cycle.” That purportedly quick ethics cycle was one of my life’s worst nightmares.

21. I was held at FLAG for four months while I was put through a process that cost me hundreds of thousands of dollars and nearly led me to have a psychotic breakdown. The Scientology process is called the “Truth Rundown,” which is usually only reserved for Sea Org members. Bruce Hines, a top-level Scientology case supervisor, said he was only aware of one other civilian Scientologist put through the Truth Rundown process. David Miscavige subsequently acknowledged that it was wrong to have subjected me to the Truth Rundown and returned at least some of my money. From morning until night, I was held in a room, put on a Scientology lie detector, and asked to admit to supposed crimes they claimed I had committed and had not disclosed. I was pounded to answer questions until I gave answers.

22. Simply put, Truth Rundown is a form of psychological torture meant to rewrite the target’s memories. It is used by Scientology when Sea Org members report an ethical issue within the organization, and Scientology wants to erase their memory and implant new memories.

23. This psychological torture continued hour after hour, day after day, for months, until I was nearing the point of psychotic breakdown. I finally gave in, rescinded all of my reports, and admitted that I was the problem in this situation (despite it not being true).

24. Finally, I was allowed to leave FLAG and return to Los Angeles, where I was forced to lie to my colleagues, friends, and family about what happened while I was in Florida.

25. I was made to make “amends” at FLAG not only to David Miscavige but to Tom Cruise. For example, I was forced to donate money to name a seat in a Scientology auditorium after Suri Cruise and to raise money for Scientology causes led by Tom Cruise.

26. After reports of terrible abuse emerged from Scientology’s international base, Golden Era Productions in Riverside County, I endured another six months of punishment for looking on the Internet and asking questions about the abuse.

27. In 2013, after my punishment, I formally and publicly left Scientology and became an outspoken public advocate for victims of Scientology. As a result, beginning in 2013 and continuing to this day, Defendant Miscavige and the other Defendants began to level a coordinated and malicious assault against me as part of their policies related to Suppressive Persons and Attackers.

28. As a Scientologist, I was forbidden to report crimes to law enforcement or file missing persons reports. After leaving Scientology, I filed a missing person report on Shelly Miscavige with the LAPD in August 2013.

29. I starred in the TV sitcom “The King of Queens” from 1998 to 2007. At the time that I resigned from Scientology in 2013, my role on “The King of Queens” had ended six years earlier.

Scientology’s Online Harassment Campaign Against Me

30. Defendants enlisted dozens of Scientologists to record videotaped messages (in Scientology production studios) to make disparaging and false claims against me — including false and defamatory statements that I was abusive to my mother and daughter, and that I am a racist. These videos continue to be posted at https://www.leahreminithefacts.org/videos/ and https://www.leahreminiaftermath.com/videos/.

31. To discredit my truthful public comments regarding Defendants, Defendants also used and manipulated my estranged and now deceased father, George Remini and his third wife, Dana, to make false statements about me, including that I am a liar, that I only wanted my name in the news, that I would not help to pay for his cancer treatments, that I turned my back on my halfsister when she was in the hospital, that I ransacked my dying grandmother’s apartment, and that I have no morals. These false statements were posted to websites created and controlled by Defendants and continue to be promoted or re-posted by Scientology social media accounts.

32. The statements my father made were unquestionably false.

33. It is false that I turned my back on my father and did not help him pay for his cancer treatments. Scientology knows it is false, because I told them. I communicated to Scientology how difficult my relationship was with my father and that I continually wanted to reestablish a relationship with him and provide support to him. Scientology has documentation in my personal and confidential files that reflect this. When my father had cancer, I flew him to Los Angeles, where he stayed with me for several months and received treatment that I paid for. I gave my father additional significant financial assistance over the years, including a $40,000 loan that he never paid back, nor did I ask for it back.

34. It is false that I ransacked my dying grandmother’s apartment. I wasn’t even there. I was — not my father — responsible for taking care of my grandmother before her death. I paid my grandmother’s rent when my father refused to. Shortly before my grandmother’s death, my father visited my grandmother’s apartment, went through her things, and took what he wanted. After her death, my sister Nicole was given costume jewelry, photo albums, and some house coats, nothing of significant monetary value.

35. It is false that I turned my back on my half-sister when she was in the hospital. On the contrary, I paid many of her bills while she was in the hospital. When she passed away, I paid for her funeral.

36. Defendants never approached me to seek comment or fact-check the false allegations my father made about me on camera. Additionally, I never had a relationship of any sort with my father’s third wife (Dana Remini). I only briefly met her twice and exchanged emails with her.

Scientology’s Additional Stalking, Surveillance, and Harassment of Me

37. In 2015, I released Troublemaker: Surviving Hollywood and Scientology, about my life in Brooklyn, growing up, my career, and my upbringing in Scientology.

38. In 2015, I traveled to New York to promote my book. During that trip, I was followed by private investigators. I had never been followed by private investigators before I left Scientology. These private investigators, whom I believe were hired by Scientology, followed me to and from my hotel, and to and from all interviews and media appearances. This hired surveillance was so intimidating that it made me fear for my physical safety. As a result, and for the first time in my life, I was forced to hire private bodyguards to ensure my safety during my book tour.

39. In addition to physically following and harassing me during my book tour, Defendants sent disparaging and threatening letters to third parties who were promoting my book, including but not limited to ABC News Senior Vice President, Tom Cibrowski and John Bentley.

40. In 2015, I was set to appear on Anderson Cooper’s CNN show to promote “Troublemaker.” Due to Scientology’s history of aggressive litigiousness, the interview was pre-taped. Before the interview began, Mr. Cooper warned me that the interview might not air. Mr. Cooper told me that when he aired a five-part series on physical abuse perpetrated by David Miscavige (Scientology: A History of Violence), he and his producers faced so many OSA attacks that they might not be willing to face a new storm of harassment. Mr. Cooper’s interview with me never aired. Since Cooper’s series aired in 2010, he has never broadcast another story about Scientology. To this day, Defendants continue to maintain attack websites against Mr. Cooper and his producers.

41. From 2016 through 2019, I created, produced, and hosted the A&E documentary series, Leah Remini: Scientology and the Aftermath (“The Aftermath”). The first episode of the first season aired on November 29, 2016. The first episode of the third season aired November 27, 2018. The final episode of the third season aired on August 26, 2019.

42. On The Aftermath, we told the stories of former members who were bankrupt, physically abused, molested, and raped by Scientologists and how the organization covered up those crimes. We told the stories of families destroyed by Scientology’s disconnection policies, and of those who suffered retaliation for reporting crimes to non-Scientology authorities.

43. Scientologists also attacked Paul Buccieri, the President & Chairman of A&E Networks Group, by creating websites on him and A&E. Contributors appearing on the series were harassed and stalked by Scientology, including through disparaging websites that were posted almost instantly. Due to this harassment, A&E was reluctant to continue The Aftermath as it would put themselves, their employees, contributors, and their advertisers at risk of further retaliation from Scientology and their agents.

44. We extended to Scientology an opportunity to comment in every episode of The Aftermath. Instead of responding to the allegations made in each episode, Scientology instead chose to attack every contributor, A&E and its staff; including sending letters to Disney, advertisers, IPC and its staff. Although they chose never to participate in the series, they often sent letters to A&E attacking me, my co-host Mike Rinder, and The Aftermath contributors. We included Scientology’s letters in the series, either by displaying the text of the letters or by reading them aloud (for example, “Here’s what Scientology has to say about Marc and Claire Headley”). In the third season of the series, Scientology began sending letters less than 24 hours before episodes were scheduled to air. We still recorded segments in which I read Scientology’s lastminute letters on camera and incorporated them into the episodes. Doing this often caused a significant disruption in the production process, which typically takes months of research, filming, editing, and legal vetting. But we did it to show fairness to Scientology, a concept that is foreign to them.

45. I also had actively practicing Scientologists appear on The Aftermath. Season two, episode four featured Ronit and Yossi Charny, who had left the organization of Scientology but continued to practice Scientology separately (and were declared Suppressive Persons for doing so). I greeted them on The Aftermath by saying: “I love that you’re here. I love you two. Even though you left the organization of Scientology, you still believe in Scientology. And you’re still delivering Scientology outside of Scientology, you’re still an auditor. . . . We are allowed to have different beliefs. I respect you, that you still believe, and you respect us, that we don’t.”

46. When I was a member of Scientology, I was asked by OSA and my Scientology handlers to sign my name to various letters in response to perceived “attacks” on Scientology. Between November 2016 and February 2019, Defendants carried out a similar operation to organize and force practicing Scientologists to write at least 500 letters seeking the cancellation of my documentary series, The Aftermath. The letters were sent to the network heads at A&E, the CEO of Disney, and innumerable advertisers and sponsors of the series, including Disney, Yahoo, Nissan, Coca-Cola, Nestle, and Expedia, to name just a few.

47. I know that between April and May 2018, Defendants, through the President’s office of Scientology’s Celebrity Centre in Hollywood, organized a meeting of Scientology celebrities and other Scientologists active in the entertainment industry. In that meeting, attendees were drilled on how to attack my credibility, based on lies, using talking points that Scientology wrote. A copy of that document shows that attendees were told to state to others that my contributors (survivors and whistleblowers) were criminals. This blanket smear was followed by the false suggestion that the National Enquirer was more credible than my documentary series. Additionally, attendees were told to say that I paid survivors and whistleblowers to appear in The Aftermath, which is also false. When I was in Scientology, I was given “dead agent packs” — Scientology-created packets of disparaging information about a Scientology enemy — which I was expected to repeat to the media. I know from my time in Scientology that this is a tactic Scientology routinely uses to discredit its enemies.

48. Attached hereto as Exhibit 1 is a true and correct copy of the talking points Scientology circulated at the Celebrity Centre meeting in 2018.

49. Defendants and Defendants’ operatives also engaged in efforts to harass and threaten anyone involved in The Aftermath, most notably, ex-Scientologists who were whistleblowers and survivors of Scientology’s abuse who agreed to be interviewed for the documentary series. Defendants then organized the harassment of non-Scientologists, like producers, crew members, support staff, editors and their family members who were not involved in the documentary series. They endured ongoing harassment by Scientologists; some of them continue to be harassed to this day via email, texts, and phone calls to their homes as well as their family member’s homes. Agents of Scientology who falsely claim to be journalists also call these individuals to solicit false information about me for Scientology’s attack websites against me.

50. I received an email from members of The Aftermath season 3 team on December 1, 2022, explaining that the entire field team was repeatedly contacted by Scientologists seeking interviews about their experiences on The Aftermath. One member said they received “easily 10 spam calls per day” and another said their entire “family (parents, brother, cousin, and uncle)” were contacted by Scientology as well. These are just a few examples of the constant barrage of harassment The Aftermath team members have faced over the years.

51. After The Aftermath ended, Scientology publicly took credit for having secured its cancellation.

52. In 2017, Defendants continued to harass and discredit me. For instance, when I appeared on the Conan O’Brien show on January 25, 2017 to promote The Aftermath, Defendants’ operatives sent Conan O’Brien a personal letter criticizing me and claiming that I was only speaking out against Scientology for the fame, money and attention. Mr. O’Brien commented that he had never before received a letter of this character in his 24 years of hosting late-night talk shows.

53. Defendants also began to falsely accuse me and my Aftermath series of inciting hate crimes. In 2016, Defendants, falsely accused me in tweets and on their websites of causing a man named Brandon Reisdorf to throw a hammer through a window at the Los Angeles office of Scientology.

54. Brandon Reisdorf appeared on Season 1, Episode 7 of The Aftermath, where he and his family publicly and unequivocally stated that it was not true that I, Leah Remini, caused Reisdorf to commit a hate crime, as Scientology alleged. What’s more, Reisdorf explained that Scientology lawyers “handed my lawyer a paragraph that would be my apology to the Church of Scientology. Basically it said that the reason why I did this was because I read books that were anti-Scientology or I went online and the media had all this stuff that was bad about Scientology, which was not true. The reason I did it is because they have destroyed my life.”

55. Although Mr. Reisdorf and his family publicly stated that I had nothing to do with his act of vandalism, Defendants continue to falsely accuse me of inciting Mr. Reisdorf’s “hate crime” and disseminate this false information on social media and on its websites to this day.

56. On January 11, 2019, Defendants falsely and maliciously accused me and The Aftermath of inciting the brutal murder of a 24-year-old Taiwanese Scientologist, Chih-Jen Yeh, in its Australian headquarters. Defendants wrote letters to the President of A&E alleging that “the murderer . . . [was] incited by A&E and the Leah Remini/Mike Rinder series.” I have publicly condemned the boy’s actions, yet Scientology and Scientology operatives with many Twitter accounts continually tweet and re-tweet false information regarding the incident.

57. During the years in which The Aftermath aired on A&E, Defendants continued to stalk and harass me. In 2017, Defendants hired International Investigative Group, Ltd. (“IIG”), a company comprised of private investigators, to surveil and follow me while I was in New York filming the 2018 movie, Second Act, and my TV series that aired from 2016 to 2018, Kevin Can Wait. Two of these private investigators were Saul Roth, a former Lieutenant in the Nassau County Police Department in New York, and Yanti (Michael) Greene.

58. I later learned that IIG was the subject of a lawsuit that alleged, among other things that Mr. Greene, one of the investigators who followed me in 2017, sexually assaulted a target of an IIG investigation. In these messages the investigators discussed:

a. Where I usually stay when I visit New York, how I usually travel, who I usually travel with, and whom I usually visit, Singer Decl. Ex. 56 at Bates No. 002278;
b. Paying off paparazzi for information on my location (“I have a paparazzi buddy . . . . I am sure he can tell me where she is;” “He’s hunting for her now—Leah”; “[H]e said she was filming in Flushing not too long ago today. . . . BAM !”), Singer Decl. Ex. 56 at Bates Nos. 002770 – 71;
c. Their movement as they followed me (“We got her last night but then lost her”; “They just pulled up;” “[W]e got her in there for sure now;” “[B]itch is late!!!”), Singer Decl. Ex. 56 at Bates Nos. 001333, 2771;
d. That “Scientologists” “might be the client,” that they have “Massive $$;” and “word is they want to kill her,” Singer Decl. Ex. 56 at Bates No. 003178 – 79, 001334;
e. That I needed to be on alert for “Scientology hit men,” Singer Decl. Ex. 56 at Bates No. 002784; and

f. Paying off paparazzi for dirt on me (“This dude know somebody in the film crew or something? [L]ooking for intel on her on set, etc . . . she rude to people . . .”), which revealed only that I was “not the nicest to paparazzi . . . But overall nice to others etc.” Singer Decl. Ex. 56 at Bates No. 002782.

59. On March 2, 2023, I filed a complaint with the Civil Rights Division of the U.S. Department of Justice. In the complaint, I described “a text message written by a private investigator hired by Scientology. This text message states that the PI heard Scientology wants to murder [me].” I asked the DOJ for help because I fear for my safety.

60. Defendants have continued to stalk, surveil, and harass me from 2020 to the present day. In July and August of 2020, my neighbors and I in Los Angeles, California, noticed a man in a white car, parked outside of my home. I hired a private investigator to look into who was surveilling my home. I learned that this man has a history of mental illness and a violent criminal record. Based on what I have learned from former top Scientology operatives, I believe Defendants armed this man with a vehicle and money to stalk and surveil me. Over the course of several weeks, at Defendants’ behest, this man rammed his car into the security gates of my community. He told residents he was waiting to get into my house, claiming he had been there several times before, and that he needed to get a bigger ladder to reach my bedroom window. He was eventually arrested and then released, at which point he called the police to falsely allege that I was holding hostages at my home. After police responded to my house, he was again arrested.

61. I know from my time in Scientology that OSA operatives are rewarded with bonus points (“stats”) for “valuable final products,” including “enemies of scientology depopularized to the point of total obliteration.” There also are stats for picketing an enemy’s place of employment, getting the press to print negative media about Scientology’s enemies, getting any litigation against Scientology dismissed, successfully framing a Scientology enemy for a crime they did not commit, getting a Scientology enemy evicted from their home, costing a Scientology enemy their job, and getting a Scientology enemy’s family to turn on them, among others. When OSA operatives succeed, Scientology publicizes them via articles on their websites, which are then posted and reposted on hundreds of social media accounts.

62. I also believe that Defendants hired Talon Executive Services, Inc. (“Talon”), a company based in Costa Mesa, California, to stalk, harass and surveil me. In 2022, employees of Talon showed up at my neighbor’s home saying I arranged for Talon to install “free security and surveillance” technology there. I had not. I believe Scientology hired Talon to plant equipment that would allow Scientology to spy on me. I only became aware of this after my neighbor called to thank me. In a recent video a Talon agent admits to a journalist that he had shared his picture with Angel (a Scientology security guard), when the journalist asked the Talon Scientology agent, Mike Ofeldt why he had taken his picture and given it to Scientology, Ofeldt stated, “You are Fair Game too.”

63. As recently as 2023, an unidentified male was recorded on video surveillance arriving at my gated community in a vehicle armed with a hammer. This unidentified man drove to my residence and smashed my mailbox, which I have to keep locked, to illegally seize my personal mail. Police responding to my call surmised that he had been sent by Scientology.

64. In addition to the physical stalking and harassment of me, Defendants’ never-ending harassment extends to my friends, family, and colleagues through a process known as a “Noisy Investigation.” Noisy Investigation is a formal Scientology policy written by L. Ron Hubbard involving pretending to conduct a criminal investigation in order to sow chaos and discredit and create fear for its targets, as well as their family members, friends, and colleagues. Noisy Investigations give the idea that an “investigation into Leah Remini” is going on.

65. OSA operatives pretending to be freelance journalists have harassed and intimidated me; my sister, Shannon Farrara, at her workplace in Los Angeles; my step-mother at her residence in North Carolina; various of my former employees and their family members; my step-sons in San Jose, my sister, Nicole Remini; and my niece and nephew in Minnesota.

66. Defendants’ OSA pseudo-journalists have written false statements and articles on Defendants’ website, Freedom Magazine, at freedommag.org. Hundreds of social media accounts then post and repost the articles on social media sites.

67. Freedommag.org includes various articles and videos aimed to defame and spread fraudulent misinformation about me. Some of these videos are entitled: “Leah Remini: A One-Woman Hate Machine”; “Leah Remini Told Dying Sister ‘Get Charity Care,’ Family Says”; and a video comparing me and the A&E network to Ku Klux Klan members who incite hate crimes.

68. This decade-long, coordinated harassment of me, as well as my friends, family, and business acquaintances, has caused me severe emotional distress, has made me fear for my physical safety and that of my family, and has caused me to lose business opportunities. It has made me hesitant to accept new work engagements that I am offered, because I am fearful that any potential employers, their employees, their family, and their friends may be unfairly targeted by Scientology by virtue of their association with me.

69. In 2015 the Defendants created a website and front group entitled, “Scientologists Taking Action Against Discrimination” (“STAND”) at: www.standleague.org. The Stand League Website is one of many websites that Defendants have used for years to attack, lie about, and harass people who are deemed enemies of Scientology. As of the time I filed this lawsuit, this website alone had posted 76 blog posts and 14 articles harassing and churning lies against me, claiming over and over that I am an “unhinged religious bigot who profits by spreading hate.” Some of these
articles are entitled:

— “Are Leah Remini and A&E responsible for the Wave of Violence Against the
Jehovah’s Witnesses’ Kingdom Halls?”
— “Leah Remini is a Disgrace to Women of Valor Everywhere.”
— “As the World Remembers the Holocaust, Bigot Leah Remini Inspires Praise of Hitler.”

These articles are repeatedly posted and reposted by Scientology-controlled accounts on social media, such that there are thousands of social media posts repeating false information about me.

70. Defendants also created https://www.leahreminithefacts.org/, an entire website designed to attack, intimidate, and harass me. The main page of the website is a narrative created at the direction of Defendants with various tabs leveling outrageous accusations against me, including but not limited to: 1) filing a false police report and then attempting to extort Scientology, and 2) abusing family members, including my half-sister, Stephani, who has since passed away. The site also includes articles entitled:

— “Leah Remini to Dying Sister: ‘Get Charity Care,’” with headline reading, “Remini’s former stepmother lets loose on how Leah ‘made a complete mockery and disaster’ of sibling Stephani Remini’s death.”
— “When Vengeance Leads to Words, Words Lead to Hate and Violence,” with headline reading, “Leah Remini has incited the very bigotry and hate that she herself was fearful of and abhorred as a Scientologist.”

71. This website includes a separate tab with 55 videos eliciting negative commentary about me from various individuals, some of whom I did not even know or have any real interaction with. During my time in Scientology, I was asked to interview and criticize people on video who were enemies of Scientology with false, disparaging information that Scientology provided me, so I know that this is part of the playbook Scientology uses against its enemies. I also saw Jessica Feshbach and Tom Davis creating a website on Marty Rathbun, who was a Suppressive Person, spreading lies about Marty.

72. The online attacks do not end there. Defendants created https://www.leahreminiaftermath.com/, with excerpts entitled, among others, “How Leah Remini Viciously Breaks up a Family,” “How Leah Remini Callously Treats her Own Family,” and “Leah’s Anti-Religious Sugar Daddy’s History of Drug Dealing and Cons.”

73. This website includes 131 videos recorded at the direction of Defendants eliciting false and defamatory commentary from individuals about me and 61 blog posts leveling false and defamatory claims, including, “Another Criminal Remini Source Returns to Jail,” “A&E and Leach Remini Spread Hate,” “Remini: Aftermath Propaganda Inciting Religious Hate,” “Leah’s AntiReligious Sugar Daddy’s History of Drug Dealing and Cons,” “Leah’s New Liar 4 Hire is a Proud Confederate Flag Lover,” “Leah Remini’s Paid Liar,” “Leah Remini’s Aftermath: Exposed As Lies Once Again,” “Leah Remini’s Family Expose Leah’s Lies,” “Leah Remini’s FRAUD,” “Total Fraud,” “Leah Remini’s Real Aftermath: Hate Speech, Threats, and Violence,” and “Leah Remini: The Dr. Jekyll and Ms. Hyde of Hollywood,” among many others. These videos and blog posts are repeatedly posted and reposted by Scientology-controlled accounts on social media, such that there are thousands of social media posts repeating false information about me.

74. This website also includes a link to a series of letters written by current members of Scientology in a concerted effort to prevent the production of The Aftermath.

75. In addition to websites created by Defendants and their employees, Scientology-run Twitter accounts actively tweet daily misinformation about me, which is in furtherance of OSA’s Suppressive Person operations. These attacks that Defendants are deploying against me amount to thousands of tweets. This constant barrage occurs all day, all night—not just directed at me, but also at my social media followers. Even a mere acquaintance of one of my stepsons, who tweeted that she was a big fan of The Aftermath, was then inundated with abusive tweets from Scientology.

76. For instance, since 2017, @standmonitor, created and run by Defendants, has posted thousands of malicious and harassing tweets about me. In March 2023 alone, they posted over 247 tweets aimed at me, includes dozens of photoshopped images of me in “I love rapists” apparel with similar fraudulent messages purporting to show my support of rapists under the hashtag, #ReminiLovesRapists.

77. Scientology-operated Twitter accounts make unsubstantiated claims that I am abusive to my daughter, who is now 19 years old. For instance, on March 22, 2023, @standmonitor tweeted that “@Leah Remini trains her daughter to beat little girls.” And @vettedfacts claims that my daughter left “her toxic home life” because I “called her daughter a c**t, all the time.” Scientologist Phil Maasen tweeted “Leah Rimjob is a hateful c*** & it shows even on her stupid, boring game show,” citing Leahreminithefacts.org, a website run by Scientology. It is absolutely untrue that my daughter “left her toxic home life” because I “call her a c**t, all the time.”

78. When my daughter left for college, I posted about it on social media. Scientology then distorted this into yet another attack on me. It also shows how closely I’m being monitored; everything I do and everything I post is being monitored 24 hours a day and twisted to be used against me.

79. Since August 2022, there are thousands of posts attacking me on Scientology’s social media accounts.

80. In the past year and in prior years, I have seen Scientology handles tweet photos taken of me when I didn’t know I was being followed or photographed. Last year, they posted photos of me at my stepfather’s birthday dinner. They have also recently posted photos of me having coffee with my Dancing with the Stars dance partner, photos of me getting lunch with my assistant, and photos that they use to body-shame me.

81. As a result of Defendants’ ongoing course of physical and social media harassment against me, I have incurred substantial economic expenses to protect me and my family’s physical and emotional health and safety.

iHeartMedia Contract

82. In addition to the conduct detailed above, Defendants’ incessant harassment of anyone or any entity affiliated with me has caused me to lose current and prospective business contracts and opportunities. It has also made me hesitant to enter into new business relationships because I fear what Scientology will do to those affiliated with me.

83. On April 13, 2018, I entered into a binding contract and profit-sharing arrangement with iHeartMedia + Entertainment, Inc., for the purpose of producing a podcast on iHeartRadio. The contract was signed by both me and Michael Biondo, the SVP Business Operations & Partnerships of iHeartMedia + Entertainment, Inc.

84. On May 1, 2020, iHeartMedia + Entertainment, Inc. and I executed an Amendment to the April 13, 2018, wherein I was to produce two podcasts — (1) a weekly “chat podcast”; and (2) a weekly podcast about Scientology. The contract gave iHeartMedia the option to renew each of the two podcasts for an additional two seasons.

85. The May 1, 2020 contract was signed by me and Mike Rinder, former high-ranking Scientology executive and OSA head, and Conal Byrne, the President of iHeart Podcasts.

86. Mr. Rinder and I co-hosted our Scientology-related podcast, called Scientology: Fair Game. This podcast included our accounts as Scientologists, including its policy and practice of inflicting abusive tactics in the name of Fair Game on those who are deemed to be enemies of Scientology. This includes Mike Rinder’s accounts of his activities as the head of Scientology’s Office of Special Affairs (OSA) and OSA’s efforts to attack those who are deemed “enemies,” “Attackers,” or “Suppressive Persons.”

87. On March 4, 2022, Defendants wrote an article and posted it at https:/www.freedommag.org/blog/iheart-produces-outrageous-bigotry-and-they-wont-talk-aboutit-0be7bf, claiming that iHeartRadio “allows Remini, in obscenity-laced and abusive language, to insult, defame and demean Scientologists.”

88. The article details the measures taken at the direction of Defendants to interfere with and terminate my contract with iHeartMedia. For instance, Defendants openly admit that they called and emailed iHeartMedia’s executive vice president and chief communications officer, producer, and the podcast audio editor in an attempt to prevent my podcast from airing.

89. Indeed, Defendants even took credit for advertisers pulling their advertising from my podcast on iHeartRadio.

90. Throughout the duration of the contract, Defendants engaged in continuous efforts to end my contract with iHeartMedia. Defendants’ agents followed and harassed podcast producers and staff until they grew so fearful that iHeartMedia made the decision to terminate the relationship with me to protect its employees and agents, even though my podcast was successful in its ratings. These producers and staff were predominately young people working from home, and were afraid
Scientology would do something to them if they continued to work with us.

91. Ultimately, iHeartMedia ended its contract with me after its last episode aired on March 7, 2022.

AudioBoom Contract

92. On August 1, 2022, I entered into a contract with AudioBoom Limited to be the exclusive audio advertising sales representative for the Scientology: Fair Game podcast for one year. The contract was signed by both me and Stuart Last, the CEO of AudioBoom Limited.

93. On August 3, 2022, STAND sent a letter to CEO Stuart Last informing him that “AudioBoom will soon be syndicating the hate podcast of two rabid anti-Scientologists.” The letter goes on to explain that “[w]hen the podcast was last running, we reached out to companies to inform them this was the defamation and bigotry they were paying for through their advertising; we heard back from chief communications and marketing officers from Verizon to eBay confirming their ads were no longer running on this hate podcast. The podcast shortly thereafter lost all commercial advertising. Audioboom advertisers deserve the decency of being informed you intend to identify their brands with defamation and hate. We will be so informing them.” The letter is signed by 39 Scientologists and was also sent to the CFO, COO, Director of Operations & Communications, VP of US Content & Partnerships, and Content Manager for Audioboom.

94. On August 10, 2022, STAND sent a letter to Julie Hansen, the US CEO of one of Audioboom’s advertisers, Babbel, addressing the podcast and stating, “[w]e trust that, like Verizon, eBay, State Farm and countless other companies, this kind of dehumanizing, hateful content violates your ad-buying guidelines and could not be further from your brand values. Audioboom syndicates hate. Please pull your advertising from this platform.”

95. On August 18, 2022, the Chief Content Officer of Audioboom, Brendan Regan, sent the following to my agents:

StandLeague.org has been contacting Audioboom’s advertisers saying that we’re promoting hate as a company by working with Fair Game. They’ve sent 6 emails to the CEO of PrettyLitter alone, a client not even associated with Fair Game. Are you aware of this and has Fair Game been impacted by this before? From the trailer that was just released it alludes that this may have been the case at iHeart.

96. On August 22, 2022, STAND sent a letter to the CEO of Candy Capital, Nick Candy, a significant investor in AudioBoom, informing him that, “[w]hen this hate podcast was streaming on its previous platform, Verizon, State Farm, eBay and others pulled their ads upon learning they were sponsoring hate. All commercial advertising then ceased on the podcast. There have been no new episodes since March 2022,” and asking that, “[a]s the company’s largest investor, we write requesting you do something about its syndication of hate.”

97. On August 30, 2022, my agents received a communication from an AudioBoom executive which marked the formal termination of my contract with AudioBoom. This
communication specifically noted that the termination of my AudioBoom contract was due to “STAND’s harassment and intimidation of AudioBoom’s employees” as well as the false and defamatory accusations made by STAND to AudioBoom and its advertisers, and the negative business implications that would reasonably ensue.

Game Show Network – People Puzzler

98. In January of 2021, I began hosting the show “People Puzzler” on the Game Show Network, a show which featured contestants answering crossword-style clues about pop culture and celebrities.

99. Defendants, in their usual course of action of attacking and harassing me, began posting open letters to the Game Show Network about how it should stop airing a show which allows an “unhinged bigot” to host, as well as claiming that the Game Show Network is employing a “rape apologist as their host” and that “Remini obviously agrees . . . ‘it’s not a big deal’ to sexually abuse women.” One open letter claimed that I had fomented “violent and deadly attacks” and asked “What’s next? A game show ‘hosted’ by a KKK leader? Neo-Nazi Jeopardy?”

100. Defendants also assailed the advertisers of the Game Show Network urging these advertisers, including but not limited to Kellogg’s and Proctor & Gamble to pull their support from the network by falsely asserting that I have inspired “hundreds of threats and acts of violence . . . including declarations of intent to . . . murder Church [of Scientology] members.”

101. Defendants’ coordinated attacks against me include the use of Twitter to post images of me juxtaposed against the logos of well-known brands, falsely stating that major brands are pulling out as advertisers of “People Puzzler” because of me. This includes photos of advertisers that have not withdrawn their support.

102. This activity is consistent with other instances in which Scientology has created the false impression that other advertisers have pulled their business from projects related to me.

103. Defendants also sent operatives claiming to be journalists to the set of People Puzzler, asking producers about “claims” that I am allegedly abusive in the workplace.

VICE News Documentary

104. In December of 2022, I was contacted by a documentary filmmaker and correspondent and producers for Vice News to make a documentary about the disappearance of Defendant Miscavige’s wife, Shelly Miscavige.

105. After two months of creative discussions between Vice and me, my agents were abruptly informed on March 2, 2022 that the project would not be moving forward. I believe that Vice ceased its discussions with me due to Defendants’ OSA Fair Game campaign.

ID/PR

106. On February 24, 2023, Scientology started a new campaign against me.

107. I have been a client of the entertainment publicity firm ID/PR for nearly a decade. During my time as a client, I would take a hiatus occasionally when I didn’t plan to do any press appearances and would therefore not pay a retainer during this time.

108. ID/PR represents hundreds of entertainment industry figures, from actors to directors to writers. It also represents production companies and other media businesses.

109. Other clients of ID/PR have, from time to time, made jokes or statements related to Shelly Miscavige or Tom Cruise. Scientology’s immediate response to those individuals was vicious attacks on social media, publicly calling these individuals, among other things, bigots.

110. This is a standard operating procedure for Scientology to evoke Scientology sympathy for being attacked by alleged religious bigots.

111. On February 24, 2023, Scientology’s OSA Operations began an attack on my publicity firm. Through official Scientology accounts and Scientology-controlled accounts, operatives began disseminating a set of conspiracy theories that were utterly false and defamatory and involved Kelly Novak, the founder of ID/PR, being the leader of an anti-Scientology cabal. Scientology also posted pictures of Ms. Novak with Harvey Weinstein, suggesting that she supported sexual abuse.

112. Scientology made false allegations that I was the head of ID/PR and covertly directed an anti-Scientology campaign from my position.

113. Scientology then started tagging the Twitter accounts of other celebrities known to be clients of ID/OR to ask them if they were aware of this non-existent anti-Scientology conspiracy being run by ID/PR.

114. Ms. Novak later direct messaged the Scientology account @StandMonitor and told them that I was no longer a client.

115. At the time, I was on hiatus with ID/PR, as I did not have any press commitments. I, however, remained a client of the firm as I had been for many years.

116. Scientology tweeted that Ms. Novak had dropped me as a client. Official Scientology and Scientology-controlled accounts cheered on this news and praised Ms. Novak for dropping me as a client.

117. Scientology further pushed the false narrative that influential entertainment industry figures abandoned me due to my “toxicity” and “bigotry.”

118. A few days after her initial direct message to @standmonitor, Ms. Novak messaged the account again to tell them that not only was I a client of ID/PR but that they were also misrepresenting her words.

119. Scientology then turned on Ms. Novak again and started attacking her and me, falsely suggesting that I had threatened Ms. Novak into retracting her previous direct message. Scientology’s harassment also extended to Ms. Novak’s office staff, who became fearful of being subject to Scientology attacks.

120. Since this defamatory campaign began, official Scientology accounts have tweeted these defamatory allegations well over 100 times.

121. Since the day I left Scientology, Defendants have stalked me, harassed me, disseminated hateful, false, and defamatory information about me, and done everything in their power to interfere with any and every business relationship in an effort to prevent me from disclosing what goes on inside Scientology. Despite this, I continue to advocate for those who have been harmed by Scientology, and I continue to speak the truth about Scientology.

122. Defendants have threatened and harmed what I hold most valuable — my family, my security, my reputation, and my career. Scientology has orchestrated, and continues to impose, a daily drumbeat of lies, misinformation, harassment, surveillance, threats, and invasions of my privacy.

123. Scientology has made the expected abuses of harassment a weight I always carry, knowing that I will be followed, my trash will be searched, my image distorted, and my college-age daughter baited. It has made virtually every contract I am offered problematic and has deterred me from seeking opportunities, for fear of what would be unleashed on my business partners — all exactly as Defendant intended.

Post-Filing, Continuing Course of Conduct by Defendants

124. In the short period of time since my Complaint was filed, I and others have been subject to continued, aggressive harassment.

125. An official statement issued by Scientology after the lawsuit asserted that my statements had “generated threats of and actual violence against the Church and its members as evidenced by multiple criminal convictions of individuals poisoned by Remini’s propaganda” and suggested that I consider emigrating to Russia.

126. Since the lawsuit was filed, there has been evidence of potential fraud flagged on several of my credit cards. The instance of fraud since the Complaint was filed is significantly higher than what my business manager has observed in the past.

127. Last month, my tutor’s business was hacked, resulting in a $15,000 loss to his business account. Prior to the filing of the lawsuit, this individual received Scientologist promotions at his home, consistent with prior instances in which Scientology has signaled its awareness that individuals are associated with me.

128. I am aware that, since the filing of the Complaint, my friend and The Aftermath cohost Mike Rinder has also been followed and surveilled. This harassment is especially egregious as Mr. Rinder is currently undergoing treatment for cancer. Knowing that my friend, while ill, is subject to this surveillance, causes me great distress.

129. I have strong reasons to believe attempts have been made to unlawfully enter my gated community in the past few months. On August 28, 2023, I opened the gate for a friend who was visiting and arrived by Uber. The gate is clearly marked with No Trespassing signs and instructions that cars should not follow others through the gate. The car behind my friend’s Uber attempted to follow it through the gate before the gate closed completely. The Uber driver noticed this attempt and stopped his car to prevent the unknown driver from entering. The unknown driver, a man not known to me or my friend, then left his vehicle, aggressively confronted the Uber driver and said he was with Amazon and needed entrance through the gate. The man was in an unmarked vehicle and wore no uniform. He verbally accosted the Uber driver and demanded entrance, which was denied, at which point he spent twenty minutes punching numbers into the call box without ever calling any resident of the neighborhood. Failing this attempt, he backed into the driveway of a nearby neighbor. The Uber driver and my friend believed he had been in this driveway the whole time waiting to gain entry as they had not seen anyone come up the street behind him. After ten minutes, he sped away. These events were reported to the property manager and the Los Angeles Police Department.

Emotional Distress and Fear for Safety

130. As a result of Defendants’ conduct over the past decade, I have experienced extreme emotional distress and have feared for my physical safety and the safety of my family and loved ones. My emotional distress is further heightened by my familiarity with Fair Game tactics from my time in Scientology, and because I know that they will stop at nothing to utterly destroy my life.

131. Defendants’ harassment campaign has touched every area of my life. When someone new befriends me, I worry that they are a plant sent by Scientology to infiltrate my life. When I am driving and notice a car behind me, I worry that it is Scientology following me — again. When my phone calls drop, I worry that Scientology is tapping my phone. When someone knocks on my door my first thought is that it is a Scientology operative. I am scared every day that I’m being followed, my phone is being tapped, or my computer is being hacked.

132. I have been forced to alter my life in many ways in response to Scientology’s constant attacks on me. I don’t let my dog outside alone because I know Scientology has a history of hurting or killing their enemies’ pets. I shred — and then burn — any important papers I am throwing away because I know Scientology has been known to reconstruct shredded paper from their enemies’ trash. Out of fear for my personal safety, I do not accept packages by myself and I avoid putting anything in my name.

133. I constantly worry for my daughter’s safety, especially when she is away at college. I have to remind her to make sure she is not being followed. When she calls me to tell me she met someone new, I have to remind her that it could be a Scientology plant trying to get close to her. I hate that I have to teach her to live in fear.

134. I have incurred substantial economic expenses to protect me and my family’s physical and emotional health and safety. This includes hundreds of thousands of dollars spent on extra security, extra staff, and therapy bills.

135. In 2015, I was so afraid for my personal safety that I directed my assistant to look into purchasing a gun.

136. This fear only increased when I learned that the private investigators Scientology hired to follow me were discussing that Scientology “wants to kill her” and that I needed to be on alert for “Scientology hit men.”

137. This fear has continued to increase as Scientology has repeatedly sent people to attempt to break into my gated community—some of whom have been successful.

138. In 2023, I moved out of my home because I don’t feel safe there knowing that Scientology has been able to infiltrate my gated community.

The Aftermath Foundation

139. The Aftermath Foundation is a separate entity that is unconnected from my documentary series, The Aftermath. I am not part of the Aftermath Foundation, nor am I on the board.

140. Aaron Smith-Levin was not a recruiter for my documentary series, Aftermath, nor did he ever work for The Aftermath.

Morgan Bradham

141. Morgan Bradham never appeared on The Aftermath.

Zyanya Marsh

142. Zyanya Marsh never appeared on The Aftermath.

Clark Huff and Jianine Giorgio Huff

143. Clark Huff and Jianine Giorgio Huff are Scientologists. Clark Huff’s wife, Jianine Giorgio Huff, worked as my personal assistant. I did not abuse Jianine. In fact, we had a good relationship while she worked for me and we parted amicably. After Jianine left my employment, she recommended that I hire her cousin, Raffy Ganimian, which I did. Raffy worked for me for several years.

144. I was generous with Jianine. When she was fired from a previous job, she returned to Los Angeles without housing, employment, or financial security. I offered her a job working for me. When her car broke down, she called me from the side of the road crying that she could not afford a new one. I bought her a new car. I helped her get a new apartment, new clothes, and new furniture. I helped her move into her new apartment. When Jianine and Clark moved into a new home, my entire family helped them move. I was invited to Jianine’s wedding shower, her wedding, her stand-up gigs, and more.

145. In correspondence to me in 2009, Jianine shared her thoughts: “[Y]ou have enhanced every aspect of my life in so many ways! . . . if I don’t tell you enough I’m so proud to work for you and I’m truly blessed to be a part of your life and to have known you. Happy bosses day. Love you so much, Jianine” and “I owe a lot of the wins I’ve had to you and really want to acknowledge you for being such an amazing . . . employer, a fellow Scientologist and a friend. . . . I really appreciate your level and care and respect for others . . . .” Additionally, in emails to me in 2013, Jianine stated: “you were a great friend to me. Thank you for that. My time with you influenced who I am today and I’m grateful for that, because in turn it made me a better person.” “Thank you – not just for the card, but for everything you’ve done for me in the past. This experience with my gram has recently shed some light on what’s important to me and – among other things – it’s important I tell the people I care about that they’re appreciated and loved as often as I can. . . . I do appreciate and love you.”

146. I maintained a good relationship with Jianine up until I left Scientology in 2013. In January 2013, I supported her emotionally through the loss of her beloved grandmother. In May 2013, I attended her bachelorette party.

147. I was always there for Jianine. It was only after I publicly departed from Scientology that Clark and Jianine started claiming that I abused Jianine.

Eric and Melinda Brownstone

148. Eric and Melinda Brownstone are Scientologists. Melinda Brownstone is Eric Brownstone’s wife. Melinda worked for me for 3 years (2005-2008) while I was a Scientologist. I did not abuse Melinda. Melinda was not a good employee. She took money from me. I fired her.

149. She was hired as my production partner for TV projects. She did not book a single project. In three years, she had one producer credit which was a project I brought her in on. Melinda created animosity in the workplace.

150. I paid Melinda a salary of over $150,000 a year. I also gave her another $50,000 to help her with debt. I paid her cell phone bill, gave her a computer, and gave her holiday bonuses. I paid for and handled her mother’s funeral. I paid for hotels for Eric and Melinda’s anniversaries and showered them with gifts for many years, including paying for Melinda’s advancement to the highest level in Scientology, which is OT-8. With another friend, I threw Melinda a baby shower. Melinda sent me many messages expressing her gratitude and friendship, including, “I wanted to thank you for all that you did leading up to and the day of the wedding. You do so much for all of us and I appreciate you so very much! Love, Melinda.” “We have so much to thank you for as of late! Thank you for the beautiful earrings, Eric’s manly ring & The stunning flowers for our Anniversary! But above ALL thank you for your genuine love & care. Your, BFF .. M~” “Dear Leah, I was thinking today that you are the cohesion to our family. I want to thank you for the love, care, support and embracive way you have adopted our whole family into your own. I love what we have & our entire group owes a great debt of gratitude & admiration for all you do, create, inspire & endure as the true team captain you are! I love you M~” “I want to acknowledge Leah’s help. Recently I was suffering from sleep deprivation due to having a new baby in the house… [Leah] supported me for several days in trying to get sleep, including making me at home in her house for two days. Thank you Leah! Love, Melinda.”

151. When I let Melinda go, I gave her a $75,000 severance. Melinda was an independent partner, not an employee, and therefore she was not entitled to any severance. Yet I still paid the severance so that she could go comfortably.

152. It was only after I left Scientology that Melinda and Eric Brownstone started claiming I mistreated them.

Kathy Oliver

153. Kathy Oliver is a Scientologist. Kathy Oliver was my manager when I was thirteen years old. I have not seen Kathy in three decades.

Don Myers

154. I do not know Don Myers. I met whom I believe to be Don Myers one time in the hallway of the Danny Masterson trial in 2023, years after The Aftermath ended. I have no knowledge of a Don Myers working as a staff photographer on The Aftermath.

Stacy Francis

155. Stacy Francis is a Scientologist. Stacy and I were friends while I was in Scientology.

156. While I was in Scientology, Stacy asked me to be godmother to her daughter; I agreed. I helped her find a place to live down the street from me because she wanted her daughter to grow up close to me. I encouraged her to move close so her children would attend schools near to me, so they could visit me regularly.

157. While I was in Scientology, Stacy needed a place to live. Stacy and her two children moved in with me.

158. While I was in Scientology, Stacy wanted me with her in the delivery room for the birth of her daughter. She had no other family or friends in the delivery room, except for me and her Scientology handler.

159. In May 2013, when Stacy was feeling overwhelmed, she asked me to take her daughter for a few days to help her out. Her daughter stayed with me for several days. We exchanged texts regularly in 2013 where she expressed gratitude for my friendship: “THANK YOU SO MUCH FOR MY BEAUTIFUL NECKLACE!!! love u!! so beautiful!! Pearls of friendship! LOVE!” “[Stacy’s son] said ‘auntie leah is so nice she gives me such nice things . . . . She is nice.’ LOL!! Out of the mouth of babes. Thank you so much. I appreciate you.” She also emailed me: “I wrote this song… I love you so much and I really dedicate it to you . . . and really appreciate you.”

160. Stacy did not accuse me of racism until after I left Scientology. Stacy only made this heinous accusation after I publicly left Scientology which is in line with Scientology’s Fair Game policies to attack their enemies with false claims.

Scientology’s False Claims That I Incited Hate Crimes

161. I never called for violence against Scientology. I never intended through any of my statements about Scientology or in conveying my story and the stories of other members of Scientology that those statements cause any sort of violence, crimes, or hate crimes.

162. I have never been investigated for inciting Brandon Reisdorf to commit crimes against the Church of Scientology. I have never been charged with or convicted of any crime in connection with Brandon Reisdorf.

163. I have never been investigated for, charged with, or convicted of inciting the murder of a Scientologist in Australia.

164. I have never been investigated for, charged with, or convicted of inciting Erin McMurtry to commit crimes against the Church of Scientology.

165. I have never been investigated for, charged with, or convicted of inciting threats or hate crimes against Jehovah’s Witnesses.

166. The episode of The Aftermath entitled “The Jehovah’s Witnesses” aired on
November 13, 2018.

167. I have never been investigated for, charged with, or convicted of inciting threats or hate crimes against Scientology.

Scientology’s False Claims That I Filed a False Police Report

168. At the time that I filed a missing person report for Shelly Miscavige, I had not seen or heard from Shelly, previously a close friend of mine, for at least six years. While I was in Scientology, I repeatedly asked about Shelly’s whereabouts. I never received an answer and was instead punished for asking. Notably, she had not attended Tom Cruise’s wedding, which I found strange because Tom Cruise was one of the most prominent Scientologist celebrities at the time, and Shelly was the wife of Scientology’s leader, who attended without her. I did not know of her whereabouts or even whether she was alive. I filed the report because I was concerned about Shelly’s health and safety.

169. I have never been investigated for, charged with, or convicted of filing a false police report.

Scientology’s False Claims that I Attempted to Extort Them

170. In 2016, in response to Scientology’s efforts to ruin my reputation and interfere with the production and airing of The Aftermath, my lawyers sent two civil demand letters to Scientology.

171. Attached hereto as Exhibit 2 is a true and correct copy of a letter from my counsel, Douglas E. Mirell, to Scientology spokesperson Karin Pouw, dated October 26, 2016.

172. Attached hereto as Exhibit 3 is a true and correct copy of a letter from my counsel, Douglas E. Mirell, to Scientology spokesperson Karin Pouw, dated November 4, 2016.

173. These letters explained that Scientology’s conduct amounted to defamation, intentional infliction of emotional distress, interference with contractual relations, and interference with prospective economic advantage. The October 26, 2016 sought $500,000 as compensation for injuries and damages suffered. The November 4, 2016 letter sought $1,000,000. It is my understanding that these letters were routine attempts to resolve a legal dispute without litigation. These letters certainly were not an attempt at extortion.

174. I have never been investigated for, charged with, or convicted of extortion.

Paul Haggis

175. I share a long history of friendship with Paul Haggis who was also a member of Scientology.

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this Declaration was executed on this 1st day of December, 2023 in Los Angeles, California.

Leah Remini

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