LEAH REMINI'S LAWSUIT AGAINST SCIENTOLOGY: HER SPECIFIC ALLEGATIONS

Yashar Ali just dropped another bombshell: Leah Remini’s new lawsuit against Scientology and its leader, David Miscavige.

It’s a huge complaint, and we’ve pulled out the specific allegations related to Leah for you to look over here.

Now, finally, we see that Leah is alleging that iHeart and Audioboom were both intimidated by Scientology out of continuing her podcast series, and so much more.

Dive in and tell us what you think Miscavige is going to regret the most about harassing this woman.

C. Leah Remini

Ms. Remini’s Indoctrination into Scientology

66. While this lawsuit concerns what happened after Ms. Remini left Scientology, her experience in Scientology helps to explain why Scientology has been so determined to silence her and others.

67. Beginning at age eight, Ms. Remini effectively lost her mother as a parent when her mother joined Scientology. Ms. Remini’s mother often left her two daughters alone so that she could devote herself to Scientology. At the age of 13, Ms. Remini and her sister were made to leave the only home they ever knew and were forced to join the Sea Org by their mother. As part of joining, they were forced to sign billion-year contracts. Ms. Remini 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. She was taught as a child to believe that her personal sacrifice would save the planet. Years of brainwashing and conditioning put Ms. Remini in a position where Scientology was the only reality for her. As with most Scientologists, Scientology was Ms. Remini’s primary caretaker. She was a member of Scientology for over 35 years.

68. During the period of time when Ms. Remini was a Scientologist, she was forced to pay for and undergo thousands of hours of Scientology training, at substantial cost to her, 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 her, a young girl, with an older male Scientologist who is required to find her “buttons” (vulnerabilities that would bother her), screamed expletives at her, made sexually suggestive remarks to her, and verbally abused her for hours in an effort to condition her 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.

69. Ms. Remini estimates that she spent over $5 million over the course of her time as a Scientologist. These funds were spent on her so-called spiritual enlightenment and those of her family members and friends. Approximately half of her funding was for services that she purchased, as from any other business. Ms. Remini’s donations also included giving to the International Association of Scientologists (“IAS”), for which there is no exchange of Scientology services. The IAS is known as David Miscavige’s war chest. Scientologists are required to pre-pay for their services and after Ms. Remini was declared a Suppressive Person, she was unable to obtain repayment of monies she had in her and her family’s Scientology accounts.

70. While Ms. Remini 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 outside groups at the behest of Scientology, she frequently was held up as an example of a model Scientologist and praised repeatedly for her contributions. She was awarded commendations by David Miscavige, Tom Cruise, and by the very people who later attacked her in Scientology-produced videos, despite repeatedly having been asked to appear in Scientology videos herself. As soon as she left and spoke out against Scientology, she was labeled by the organization she 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 and who have spoken out, and for non-Scientologists who have made a joke about Scientology, reported crimes against, or advocated for victims of Scientology.

71. Scientology's campaign to destroy Ms. Remini began in 2006, seven years before she publicly left Scientology in the summer of 2013. This background is described solely to provide context for Scientology’s attacks on Ms. Remini after she publicly left Scientology.

72. In 2006, Ms. Remini and her husband 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.”

73. 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, Ms. Remini 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.

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

75. Ms. Remini witnessed other behavior at the wedding that set off red flags for her, including unethical contacts between various Scientology executives and others at the wedding which she understood to be forbidden by Scientology teachings.

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

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

78. When Ms. Remini returned to Los Angeles, she 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.

79. Ms. Remini was told that before she could receive the services she had planned on getting while there, she would undergo a quick "ethics cycle". That purportedly quick ethics cycle was one of her life's worst nightmares.

80. Upon arrival, Ms. Remini was presented with dozens of internal reports from Scientologists complaining about her behavior at the wedding. It was clear to Ms. Remini that she was being punished for asking where Shelly Miscavige was and for filing reports on David Miscavige and others.

81. Ms. Remini was held at FLAG for four months while she was put through a process that cost her hundreds of thousands of dollars and nearly led her 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 Ms. Remini to the Truth Rundown and returned at least some of her money.

82. 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.

83. After months of psychological torture, Ms. Remini was nearing the point of psychotic breakdown. She finally gave in, rescinded all of her reports, and admitted that she was the problem in this situation (despite it not being true).

84. Finally, Ms. Remini was allowed to leave FLAG and return to Los Angeles, where she was forced to lie to her colleagues, friends, and family about what happened while she was in Florida.

85. Ms. Remini was made to make "amends" at FLAG not only to David Miscavige but to Tom Cruise. For example, she was forced to donate money to name a seat in a theater after Suri Cruise and was to raise money for donation to Scientology causes led by Tom Cruise.

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

87. After her punishment, Ms. Remini resigned from Scientology in 2013.

88. After leaving Scientology, Ms. Remini filed a missing person report on Shelly Miscavige, who has not been seen in public for 17 years.

Leaving Scientology - Fair Game

89. In 2013, Ms. Remini formally and publicly left Scientology and became a 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 one of their most coordinated and malicious assaults against Ms. Remini as part of their policies related to Suppressive Persons and Attackers.

90. Defendants enlisted dozens of current and former Scientologists to record videotaped messages (in Scientology production studios) to make disparaging and false claims against Ms. Remini—including false and defamatory statements that she was abusive to her mother and daughter, and that she is a racist. These videos continue to be posted at

https://www.leahreminithefacts.org/videos/ and https://www.leahreminiaftermath.com/videos/.

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

92. The statements Mr. Remini made were unquestionably false and contradicted by email communications and financial records. Defendants never approached Ms. Remini to seek comment or fact-check the false allegations her father made about her on camera. Additionally, Ms. Remini never had a relationship of any sort with her father’s third wife and only briefly met her twice. Yet Scientology used Dana Remini as a reliable source of information about Ms. Remini.

93. In 2015, Ms. Remini released Troublemaker: Surviving Hollywood and Scientology. Ms. Remini’s book, a memoir exposing Scientology’s abusive conduct, went on to become a New York Times bestseller. Ms. Remini’s critical and successful memoir further escalated Defendants’ abusive tactics against her.

94. While Ms. Remini was in New York in 2015 to promote her book, she became aware that she was being followed by private investigators hired by Defendants. These private investigators followed Ms. Remini to and from her hotel and to and from all interviews and media appearances. Defendants’ hired surveillance, consistent with Scientology directives, was so intimidating that it made Ms. Remini fear for her physical safety. As a result, Ms. Remini, for the first time in her life despite being a public figure, was forced to hire private bodyguards to ensure her safety during her book tour.

95. In addition to physically following and harassing Ms. Remini during her book tour, Defendants sent disparaging and threatening letters to third parties who were promoting Ms. Remini’s book, including but not limited to ABC News Senior Vice President, Tom Cibrowski and John Bentley. The intent of the letters was to silence Ms. Remini, damage her reputation, and in turn, her ability to earn income from her book.

96. In 2015, Ms. Remini 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 so that it could be vetted by CNN’s legal department. Before the interview began, Mr. Cooper warned Ms. Remini that the interview might not air. Mr. Cooper told Ms. Remini that when he aired a five-part series on physical abuse being 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. 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.

97. From 2016 through 2019, Ms. Remini created, produced and hosted the award winning A&E documentary series Leah Remini: Scientology and the Aftermath (“Aftermath”). This documentary series told the stories of former members who were bankrupt, physically abused, molested, and raped by Scientologists and how the organization covered up those crimes. They told the stories of those whose families have been destroyed by Scientology’s disconnection policies, and of those who suffered retaliation for reporting crimes to non-Scientology authorities. The documentary series won two Emmy awards, a Producers Guild Award, Independent Documentary Award (Truth to Power Award), two Gracie awards (Alliance for Women in Media Foundation), and the Barbara Blaine Trailblazer Award from Child USA, again intensifying Defendants’ efforts to silence and discredit her. Scientologists have also attacked Paul Bucceri, the President & Chairman of A&E Networks Group, by creating websites on him and A&E. Due to this harassment A&E was reluctant to put themselves and their employees, their advertisers at risk out of fear of further retaliation from Scientology and their agents. Contributors appearing on the series were thereafter harassed and stalked by Scientology, including through disparaging websites that were posted almost instantly.

98. Scientology was provided an opportunity to comment in every episode. Yet, Defendants have done everything in their power to sabotage Ms. Remini’s The Aftermath series. Between November 2016 and February 2019, Defendants designed an operation to organize and force practicing Scientologists to write at least 500 letters seeking the cancellation of Ms. Remini’s show. 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.

99. 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 Ms. Remini’s 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 Ms. Remini’s contributors (survivors and whistleblowers) were criminals. This blanket smear was followed by the false suggestion that the National Enquirer was more credible than Ms. Remini’s documentary series. Additionally, attendees were told to say that Ms. Remini paid survivors and whistleblowers to appear in her documentary series, which is also false.

100. In addition to these hundreds of letters, Scientologists, at the urging of Defendants, and in accordance with their Suppressive Person, OSA Network directives, HCOBs, HCOPLs and Fair Game policies, OSA created a front group called the Interfaith Alliance to create the appearance that religious leaders found the series one of religious bigotry. This group, none of whom were actual clergy and all of whom were Scientologists, stood outside of the A&E corporate offices and picketed, demanding cancellation of Ms. Remini’s documentary series, falsely claiming that she incited bigotry and hate crimes, including, but not limited to, murder.

101. 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 Ms. Remini for Scientology’s attack websites against her. After The Aftermath ended, Scientology publicly (but falsely) took credit for having secured its cancellation.

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

103. Defendants also began to intentionally and fraudulently accuse Ms. Remini and her Aftermath series of inciting hate crimes. In 2016, Defendants, well aware of the falsehoods being leveled at Ms. Remini, accused Ms. Remini in tweets and on their websites of causing a man named Brandon Reisdorf, whose parents were former Scientologists, to throw a rock through a window at the Los Angeles office of Scientology. Mr. Reisdorf, who was forced to disconnect from his brother and parents, was in the midst of a mental health crisis. Scientology policies ban any sort of psychiatric or psychological treatment.

104. Both Mr. Reisdorf and his family have publicly stated that Ms. Remini had nothing to do with this episode—yet Defendants continue to stand by their fraudulent accusations and continue to disseminate this false information on social media and on its websites to this day.

105. And on January 11, 2019, Defendants falsely and maliciously accused Ms. Remini and The Aftermath of inciting the brutal murder of a 24-year-old Taiwanese Scientologist, Chih-Jen Yeh, in its Australian headquarters. Mr. Yeh was working as a security guard and was escorting a woman to begin her program to join the Sea Org, when the woman’s 16-year-old son stabbed and murdered Mr. Yeh. Without any basis, 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.” Ms. Remini has publicly condemned the boy’s actions, yet Scientology and Scientology operatives with over 200 Twitter accounts continually tweet and re-tweet intentionally false and libelous information regarding the incident. A sampling of these tweets is below.

106. During the years in which Aftermath aired on A&E, Defendants continued to stalk and harass Ms. Remini. In 2017, Defendants hired International Investigative Group, Ltd. (“IIG”), a company comprised of private investigators, to surveil and follow Ms. Remini while she was in New York filming the 2018 movie, Second Act, and her TV series that aired from 2016 to 2018, Kevin Can Wait. [See April 21, 2021 Affidavit of Saul Roth in Smith v. International Investigative Group Ltd., et al, NY Sup. Ct. No. 607393/2019 at 3.] Two of these private investigators were Saul Roth, a former Lieutenant in the Nassau County Police Department in New York, [See April 21, 2021 Affidavit of Saul Roth at ¶¶ 3, 13.] and Yanti Greene. Messages obtained between Mr. Greene and Mr. Roth in unrelated litigation reveal that “word is they [Scientology] want to kill her.” [Ex. 25 to Memorandum of Law in Support of Motion for Partial Summary Judgment in the case of Smith v. Int’l Investigative Group Ltd., Case No. 607393/2019 (Nassau Cty., NY, May 27, 2021) at Bates Nos. 001329-334.]

107. Defendants continued to stalk, surveil, and harass Ms. Remini from 2020 to the present day. In July and August of 2020, Ms. Remini and residents of her neighborhood in Los Angeles, California noticed a man in a white car, parked outside of Ms. Remini’s home. After reasonable investigation, it was discovered that this man has a history of mental illness and a violent criminal record. Upon information and belief, provided by former top Scientology operatives, Defendants armed this man with a vehicle and money to stalk and surveil Ms. Remini. Over the course of several weeks, at Defendants’ behest, this man rammed his car into the security gates of Ms. Remini’s community and asked residents for Ms. Remini’s address, saying he was waiting to get into her house, falsely claiming he had been there several times before, and that he needed to get a bigger ladder in order to reach her bedroom window. He was eventually arrested and then released, at which point he called the police to allege that Ms. Remini was holding hostages at her home. After police responded to Ms. Remini’s house, he was again arrested.

108. Former Scientology operatives have acknowledged that Scientology has a practice of seeking out individuals with mental illness or who are homeless or addicted to drugs, and other vulnerable people in order to harass its enemies.

109. To incentivize successful outcomes, OSA operatives are rewarded with bonus points for “valuable final products,” including “intelligence furnished that effectively guides the progress of Scientology”; “public matters and individuals which impede human liberty investigated and exposed”; and “enemies of scientology depopularized to the point of total obliteration.” There also are points for pickets, negative media, litigation filed, evictions, and government actions, among others.

110. Upon information and belief, Defendants also hired Talon Executive Services, Inc. (“Talon”), a company based in Costa Mesa, California, to stalk, harass and surveil Ms. Remini. In 2022, employees of Talon showed up at Ms. Remini’s neighbor’s home under the guise that Ms. Remini arranged for Talon to install “free security and surveillance” technology there. In reality, and based upon information and belief, Scientology had hired Talon to plant equipment that would allow Scientology to spy on Ms. Remini. Ms. Remini only became aware of this ruse after her neighbor called to thank her.

111. As recently as 2023, an unidentified male was recorded on video surveillance arriving at Ms. Remini’s gated community in a vehicle armed with a hammer. This unidentified man drove to Ms. Remini’s residence and smashed her mailbox, which she has to keep locked, to illegally seize Ms. Remini’s personal mail. Police responding to Ms. Remini’s call surmised that he had been sent by Scientology and, upon information and belief, he was sent by Defendants.

112. In addition to the physical stalking and harassment of Ms. Remini, Defendants’ never-ending harassment extends to Ms. Remini’s 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. [See Hubbard Communications Office HCO Executive Letter of Sept. 5, 1966 entitled “How do to a NOISY]

113. OSA operatives pretending to be freelance journalists have implemented Noisy Investigations against Ms. Remini to harass her. Scientology has harassed Ms. Remini; Ms. Remini’s sister, Shannon Farrara, at her workplace in Los Angeles; Ms. Remini’s step-mother at her residence in North Carolina; her deceased father, George Remini; various of Ms. Remini’s former employees and their family members; her step-sons in San Jose (and a friend of one step-son who tweeted that he was a big fan of Aftermath); her sister, Nicole Remini; and her niece and nephew in Minnesota. In each case, Defendants’ agents claim to be reporters who are doing a “story” about Ms. Remini and indicate that they have information that Ms. Remini was abusive Investigation,” which states in pertinent part: “Here’s what you do. Soon as one of these threats starts you get a Scientologist or Scientologists to investigate noisily. You find out where he or she works or worked, doctor, dentist, friends, neighbors, anyone and phone em up and say I am investigating Mr./Mrs…for criminal activities…It doesn’t matter if you don’t get much info. Just be NOISY –it’s very odd at first but makes fantastic sense and WORKS.” her family and friends, and then attempt to get Ms. Remini’s friends and family to comment on the fake accusations or provide disparaging information.

114. Defendants’ OSA pseudo-journalists have written false statements and articles on Defendants’ website, Freedom Magazine, at freedommag.org.

115. Freedommag.org includes various articles and videos aimed to defame and spread fraudulent misinformation about Ms. Remini. 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 Ms. Remini and the A&E network to Ku Klux Klan members who incite hate crimes.

116. This decade-long, coordinated harassment of Ms. Remini, as well as her friends, family, and business acquaintances, has caused severe emotional distress to Ms. Remini, has made her fear for her physical safety and that of her family, and has caused the loss of business opportunities, as laid out below.

Social Media Attacks Against Ms. Remini

117. In addition to physical stalking and harassment, from 2013 to the present day, Defendants have implemented a mass coordinated social media effort against Ms. Remini to spread false and malicious information about her through hundreds of Scientology-run websites and social media accounts.

118. Hundreds of websites and social media accounts were created by Defendants, and/or those working at the direction of Defendants, to harass, embarrass, shame, and defame Ms. Remini. Each website was more explicit and offensive than the last, containing attacks on Ms. Remini’s character, her work, her family, her daughter, and every facet of her life. These hundreds of websites are part of a larger group of websites against enemies of Scientology, which include over 5,000 separate domains, and include the same coordinated messaging dictated by OSA.

119. For instance, 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. This website has posted 76 blog posts and 14 articles harassing and churning lies against Ms. Remini, claiming over and over that she is 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.” [This accusation is particularly egregious, as Ms. Remini’s mother is Jewish.]

120. Defendants also created https://www.leahreminithefacts.org/, an entire website designed to attack, intimidate, and harass Ms. Remini. The main page of the website is a narrative created at the direction of Defendants with various tabs leveling outrageous accusations against Ms. Remini, including but not limited to: 1) filing a false police report and then attempting to extort Scientology, and 2) abusing family members, including her half-sister, Stephani, and father, George Remini, both of whom have 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.”

121. This website includes a separate tab with 55 videos recorded at the direction of Defendants eliciting negative commentary from individuals, some of whom Ms. Remini did not even know or have any real interaction with.

122. 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.”

123. This website includes 131 videos recorded at the direction of Defendants eliciting false and defamatory commentary from individuals regarding Ms. Remini 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 Anti-Religious 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.

124. 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 Aftermath.

125. In addition to websites created by Defendants and its employees, there are hundreds of Scientology-run Twitter accounts that are actively tweeting daily misinformation about Ms. Remini in furtherance of the Suppressive Person and OSA operations and attacks that Defendants are deploying against her. Based upon information and belief, these individuals create Twitter accounts for the purpose of harassing Ms. Remini and other whistleblowers and advocates who have been deemed Suppressive Persons or attackers of Scientology, buy followers on social media, follow each other’s accounts, and coordinate their attacks on Ms. Remini.

126. For instance, since 2017, @standmonitor, created and run by Defendants, has posted thousands of malicious and harassing tweets about Ms. Remini. In March 2023 alone, they have posted over 247 tweets aimed at Ms. Remini, includes dozens of photoshopped images of Ms. Remini in “I love rapists” apparel with similar fraudulent messages purporting to show Ms. Remini’s support of rapists under the hashtag, #ReminiLovesRapists. Just a few of these photos is included herein, but hundreds of similar images appear under Defendants’ Twitter accounts:

127. Scientology-operated Twitter accounts make unsubstantiated claims that Ms. Remini is abusive to her daughter, who is now 18 years old. For instance, on March 22, 2023 @standmonitor tweeted that “@Leah Remini trains her daughter to beat little girls.” And @vettedfacts claims that Ms. Remini’s daughter left “her toxic home life” because Ms. Remini “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.

128. Defendants, or individuals directed by Defendants, have tweeted untrue and highly damaging claims that Ms. Remini has involuntarily committed her college daughter to a psychiatric facility. These tweets also included questions like “Where is Sofia,” leaving Ms. Remini to fear that Scientology operatives and agents were trying to track down her daughter’s location. These claims have caused Ms. Remini to fear for the safety of her daughter.

129. Defendants, or individuals directed by Defendants, also have control over hundreds of Twitter handles which are regularly used to attack Ms. Remini.35 Indeed, while there are virtually hundreds of Twitter accounts controlled and run by Defendants which actively tweet false and defamatory information against Ms. Remini on a daily, weekly or monthly basis, 31 accounts have tweeted 1,398 tweets about and against Ms. Remini in March 2023 alone. A few examples of the many defamatory tweets from other Twitter handles are below:

Defendants, that have spread lies and hate against Ms. Remini in the month of March alone, see :e.g. @BFTSTANDleague; @CESTANDleague; @DMStandLeague; @evamahoney101; @FreedomEthics; @gsstandleague; @standmonitor; @sliverson; @JMStandLeague; @JGStandLeague; @jimrossmeskimen; @JohnAllender5; @JPdarkn; @DorisPansy534; @SoulPrisoner; @KiwiBoy2020; @lauriejbart; @LCStandLeague; @MediaEthicsChk; @MKTSTANDleague; @LW_STANDleague; @QReligious; @qcus007; @STANDleague; @ScientologyDad; @EndBigotryNow2; @ItsBklynSteve; @parismorf; and @XanthiaHare.

130. As a result of Defendants’ ongoing course of physical and social media harassment against Ms. Remini, Ms. Remini has incurred substantial economic expenses to protect her physical and emotional health and safety – something she has never done despite being in the public eye for most of her career.

iHeartMedia Contract

131. In addition to the conduct detailed above, Defendants’ incessant harassment of anyone or any entity affiliated with Ms. Remini has caused Ms. Remini to lose current and prospective business contracts and opportunities.

132. On April 13, 2018, Ms. Remini 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 Ms. Remini and Michael Biondo, the SVP Business Operations & Partnerships of iHeartMedia + Entertainment, Inc.

133. On May 1, 2020, iHeartMedia + Entertainment, Inc. and Ms. Remini executed an Amendment to the April 13, 2018 contract, wherein Ms. Remini 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.

134. The May 1, 2020 contract was signed by Ms. Remini and Mike Rinder, a former Scientologist, and Conal Byrne, the President of iHeart Podcasts.

135. Ms. Remini and Mr. Rinder co-hosted their Scientology-related podcast, called Scientology: Fair Game. This podcast included their accounts of Scientology, 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.

136. On March 4, 2022, as part of its Fair Game campaign and in order to derail her podcast, Defendants directed and controlled the publication of an article at https://www.freedommag.org/blog/iheart-produces-outrageous-bigotry-and-they-wont-talk-about-it-0be7bf, claiming that iHeartRadio “allows Remini, in obscenity-laced and abusive language, to insult, defame and demean Scientologists.”

137. The article details the measures taken at the direction of Defendants to interfere with and terminate Ms. Remini’s 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 Ms. Remini’s podcast from airing.

138. Indeed, Defendants even took credit for advertisers pulling their advertising from Ms. Remini’s podcast on iHeartRadio.

139. Throughout the duration of the contract, Defendants engaged in continuous efforts to end Ms. Remini’s contract with iHeartMedia. Defendants directed individuals to follow and harass podcast producers until those producers grew so fearful that iHeartMedia made the decision to terminate the relationship with Ms. Remini to protect its employees and agents, even though the show was successful in its ratings.

140. Ultimately, iHeartMedia ended its contract with Ms. Remini after its last episode aired on March 7, 2022.

AudioBoom Contract

141. On August 1, 2022, Ms. Remini 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 Ms. Remini and Stuart Last, the CEO of Audioboom Limited.

142. On August 3, 2022, at the direction of Defendants, STAND sent a letter to CEO 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.

143. On August 10, 2022, at the direction of Defendants, 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.”

144. On August 18, 2022, the Chief Content Officer of Audioboom, Brendan Regan, sent the following to agents of Ms. Remini: 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.

145. On August 22, 2022, at the direction of Defendants, 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.”

146. On August 30, 2022, Ms. Remini’s agents received a communication from an Audioboom executive which marked the formal termination of Ms. Remini’s contract with AudioBoom. This communication specifically noted that the termination of Ms. Remini’s AudioBoom contract was due to “STAND’s harassment and intimidation of Audioboom’s employees” as well 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

147. In January of 2021, Ms. Remini 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.

148. Defendants, in their usual course of action of attacking and harassing Ms. Remini, 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.”

149. 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 Ms. Remini has inspired “hundreds of threats and acts of violence…including declarations of intent to…murder Church [of Scientology] members.”

150. Defendants also use Twitter to post images of Ms. Remini juxtaposed against the logos of well-known brands as part of an effort to leave the impression that major brands are pulling out as advertisers of “People Puzzler” due to Ms. Remini, including advertisers that have not withdrawn their support.

151. Defendants also sent OSA operatives claiming to be journalists to the set of People Puzzler, asking producers about “claims” that Ms. Remini is allegedly abusive in the workplace.

152. Production on the fourth season of People Puzzler should be underway. However, production has not started, and Ms. Remini has not been contacted to begin the new season, which, upon information and belief, is the result of the ongoing harassment experienced by the network.

VICE News Documentary

153. In December of 2022, Ms. Remini 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, Shelley Miscavige.

154. After two months of creative discussions between Ms. Remini and Vice, Ms. Remini’s agents were abruptly informed on March 2, 2022, that the project would not be moving forward. Based upon information and belief, Vice ceased its discussions with Ms. Remini due to Defendants’ Fair Game campaign.

ID/PR

155. On February 24, 2023, Scientology started a new campaign against Ms. Remini.

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

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

158. 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.

159. This is a standard operating procedure for Scientology to evoke Scientology sympathy for being attacked by alleged religious bigots.36

160. On February 24, 2023, Scientology’s OSA Operations began an attack on Ms. Remini’s 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.

161. Other conspiracy theories included the false allegation that Ms. Remini was the head of ID/PR and covertly directed an anti-Scientology campaign from her position.

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

163. All of these tweets, which eventually grew to over 100, were intended to get Ms. Novak to buckle under the pressure and drop Ms. Remini as a client, which would further isolate Ms. Remini in the entertainment industry.

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

165. At the time, Ms. Remini was also on hiatus with ID/PR, as she did not have any press commitments. She, however, remained a client of the firm as she had been for many years.

166. Scientology tweeted that Ms. Novak had dropped her as a client. Official Scientology and Scientology-controlled accounts cheered on this news and praised Ms. Novak for dumping Ms. Remini.

167. Scientology further pushed the idea that influential entertainment industry figures abandoned Ms. Remini due to her “toxicity” and “bigotry.”

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

169. Scientology then turned on Ms. Novak again and started attacking her and Ms. Remini, falsely suggesting that Ms. Remini had threatened Ms. Novak into retracting her previous direct message.

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

171. Since the day Ms. Remini left Scientology, Defendants have stalked Ms. Remini, harassed Ms. Remini, disseminated hateful, false, and defamatory information about Ms. Remini, and done everything in their power to interfere with any and every business relationship in an effort to prevent her disclosing what goes on inside Scientology.

172. While Defendants have not succeeded in “muzzl[ing],” “obliterat[ing],” nor “ruin[ing] utterly,” they have threatened and harmed what Ms. Remini holds most valuable—her family, her security, her reputation, and her career. Scientology has orchestrated, and continues to impose, a daily drumbeat of lies, misinformation, harassment, surveillance, threats, and invasions of Ms. Remini’s privacy.

173. Scientology has made the expected abuses and harassment a weight Leah Remini always carries, knowing that she will be followed, her trash will be searched, her image distorted, and her college-age daughter baited. It has made virtually every contract Ms. Remini is offered problematic, and deterred her from seeking opportunities, for fear of what would be unleashed on her business partners—all exactly as Defendants intended.

174. Defendants have committed a litany of legal violations that must be restrained and remedied. Defendants’ constant, life-altering, tortious behavior cannot continue…

V. CAUSES OF ACTION

COUNT I: CIVIL HARASSMENT

COUNT II: STALKING - CALIFORNIA CODE § 1708.7

COUNT III: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

COUNT IV: TORTIOUS INTERFERENCE WITH CONTRACTAL RELATIONSHIP

COUNT V: INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE

COUNT VI: DEFAMATION & DEFAMATION PER SE

COUNT VII: DEFAMATION BY IMPLICATION

COUNT VIII: FALSE LIGHT

COUNT IX: DECLARATORY JUDGMENT- CALIFORNIA CODE CIVIL PROCEDURE § 1060

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