Leah Remini wants an injunction to muzzle Scientology, and now we have the church’s reply

[Leah Remini and Scientology attorney William Forman]

We told you that on Friday, Judge Randolph Hammock told both sides in Leah Remini’s lawsuit against the Church of Scientology to stop burying him in filings ahead of what is now an important January 16 hearing.

But Scientology managed to get quite a few filings in that morning before the judge shut things down, and one of them was something we’d been anticipating: Scientology’s response to Leah’s motion for a preliminary injunction.

Leah filed her lawsuit on August 2, and even before Scientology responded to it she filed the motion, saying that the harassment against her and co-star Mike Rinder and also the Aftermath Foundation had only increased, and she asked the court to issue an injunction to keep Scientology from harassing and stalking her while the lawsuit is going on.

For now, the motion for the injunction is scheduled to be heard on January 19.

One of the documents Scientology got in under wire Friday was its response to Leah’s motion, and as you can imagine, it is written in Scientology’s typical angry style by attorneys William Forman (for Church of Scientology International) and Matthew Hinks (for the Religious Technology Center).

We thought you’d want to get a flavor of it, so here’s the document’s full introduction:

“Some people’s idea of free speech is that they are free to say what they like, but if anyone says anything back, that is an outrage.” – Winston Churchill.

That is all Plaintiff’s Motion for Preliminary Injunction (“Motion”) is about – her outrage that Defendants spoke back after her years of attack. The Motion’s numerous defects show that it is born in outrage and not in any facts or law. To list just some of the fatal problems with the Motion:

— It seeks an impermissible prior restraint of speech.
— It identifies no speech – such as a credible threat of violence – that could ever be subject to prior restraint.
— It identifies no conduct that amounts to a credible threat of violence.
— With perhaps one exception, it describes alleged conduct directed towards third persons, not Plaintiff.
— It does not provide a single piece of evidence showing Defendants are responsible for any of the alleged conduct. (And they are not).
— It seeks relief on a claim this Court has no jurisdiction to hear.
— It seeks relief for conduct outside of the Court’s jurisdiction.
— It presents no evidence of irreparable harm.
— It is impermissibly vague both as to the conduct and/or speech to be restrained, and the persons to be “protected.”

The Motion is so patently deficient that motives beyond its stated grounds must be considered. It is another round of transparent, self-generated publicity for Plaintiff and a vehicle to abuse the litigation privilege to falsely accuse Defendants of crimes. Perhaps the biggest giveaway is Plaintiff’s argument that the Court should just grant the injunction because it requests “only that Defendants cease conduct that is unlawful,” (Motion at 9:5-6). That formulation is meaningless. The proposition that a party should not engage in unlawful conduct is quite literally the law and cannot in itself warrant granting an injunction. But a meaningful injunction is not the objective. Plaintiff wants an order – any order – to show her followers that the Church has been enjoined from unspecified “unlawful conduct” and therefore must be doing something bad. The Court should not let itself be used by Plaintiff as a megaphone in her latest public relations stunt.

Scientology says it is holding Leah “to account” for “hate speech,” and for her “unconstitutional attempt to silence” the church through her lawsuit.

But the motion for a preliminary injunction goes even farther than that, they say.

Leah’s motion asks the court to enjoin Scientology from harassing, attacking, and interfering with her or her family. Scientology responds that these are just “euphemisms for speech that [Remini] dislikes.”

For example, Leah complained that various people “believed to be connected to Scientology have submitted complaints to Instagram about me and my posts,” and labeling them hate speech. These complaints, she says, could risk her losing her Instagram account and her ability to advocate for victims.

Scientology counters that Leah “wants this Court to stop anyone from complaining to Instagram about her manifest bigotry towards Scientology. Because speaking the truth is bad for her brand.”

As for incidents of people knocking at Leah’s mother’s door, or loitering outside her manager’s house, or someone who claimed to be an Amazon delivery driver to get into her gated community, Scientology says there isn’t “an iota of evidence” that any of these incidents were connected with the church.

Later, after arguing that the law is not on Leah’s side, Scientology then swears under oath that it is not behind several incidents that Leah had cited in her motion.

They include: A man claiming to be an Amazon delivery person who tried to get into Leah’s gated community. Two men who knocked on her mother’s door. A broken window at her mother’s restaurant. And unknown people texting Leah’s sister and asking for contact info for Leah.

“Defendants state under oath that they were not involved in these alleged incidents,” Scientology states, and then dismisses them as random events: “This is just life. People knock on doors; Amazon delivers packages; people get spam texts. Not only is there ‘no there there,’ Plaintiff’s only ‘proof’ that Defendants are responsible for any of this is her speculative and bigoted say-so.”

Well, as we’ve pointed out before, both sides are really letting loose at each other in these filings, and we’re really wondering how Judge Hammock is going to weigh in when he deals with Scientology’s motion to strike on Tuesday (Jan 16) and then when he looks at this motion for a preliminary injunction just three days later.

It seems like a lot is at stake, and we’ll be watching it closely.

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Bonus items from our tipsters

We’re sure this was a hoot — Watching Scientology TV at the Ventura org? Sounds major. Perhaps someone could go by next week to see how much fun people are having.

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