Leah Remini filed her lawsuit against the Church of Scientology on August 2. Since then, she’s made several more filings, updating the complaint with new allegations, asking for an injunction to stop the church from continuing to harass her, and even asking for a new judge.
During that time, we’ve been waiting to see what Scientology’s response to the lawsuit was going to be, and now we have it. And what a response. Scientology’s reliable duo, attorneys William Forman and Matthew Hinks, are aiming at the lawsuit with both barrels, asking for a large part of it to be stricken, and, under anti-SLAPP rules for their fees.
What their response essentially boils down to is this: Yes, Scientology called Leah Remini names online, but only because she called Scientology names first.
We know you like to have the details, so we’re going to excerpt large parts of their filings verbatim. So here we go.
I. INTRODUCTION
After being expelled from the Church of Scientology over a decade ago for unethical conduct, Plaintiff Leah Remini (“Plaintiff”) made a lucrative career spewing hate and inspiring violence against the Church of Scientology, its parishioners, and the ecclesiastical leader of the Scientology religion. She has done this through her autobiography, a cable television show, podcasts, and appearances on broadcast television and radio. She has used those platforms to call the Church “pure fucking evil” and its parishioners “sick assholes,” “fucking like body snatchers,” and “morally depleted,” and even to falsely accuse the ecclesiastical leader of the religion of unidentified “crimes.”
Plaintiff candidly admits that she spins hate for cash, boasting to ABC News, “I don’t work for free.” She admits her anti-Scientology TV show—supposedly “investigative journalism”—was a sham: “Listen, that’s how it works, honey, doll, that’s how you do it. It’s not reality. I work out—I plan out all these episodes and we figure them out beforehand on who’s going to say what…” [Proprietor’s note: This is a claim made by Marty Rathbun, not any recorded utterance by Remini herself.] Yet the harm and terror she has caused is all too real: Since Plaintiff started her hate campaign, the Church of Scientology, its ecclesiastical leader, clergy, and parishioners have endured more than 500 acts of hate, vandalism, incidents of harassment, and threats of violence and death. Within an hour of the debut of the second season of Plaintiff’s TV show, the Church received these threats and others:
- “You all are dead. I am gonna murder all of you pig cult bastards and blow up all your building. You are fucked.”
- “All churches are going to be gone all every asshole Scientologist dead.”
Refusing to remain silent in the face of the threats and violence Plaintiff inspired, the Church fought back. It shined a light on Plaintiff’s ugliness, showing the world the degrading comments Plaintiff has made about Scientologists and their ecclesiastical leader. It let her supporters know that they were giving comfort to an anti-religious bigot. It detailed the hundreds of threats and crimes inspired by Plaintiff’s speech. And it did all of this committed to a principle alien to Plaintiff—the Church always told the truth. Everything the Church has said about Plaintiff’s hate and bigotry is documented—most often out of the mouth of Plaintiff herself.
Now that she is on the receiving end of speech, Plaintiff has filed this Complaint and the attendant Application for Preliminary Injunction (“PI Application”) to stifle all dissent. This lawsuit is nothing but an attempt by Plaintiff to stop Defendants Church of Scientology International (“CSI”) and Religious Technology Center (“RTC,” and collectively with RTC “Defendants” or the “Church”) from responding to her hateful attacks with truthful speech. Each cause of action she alleges seeks to impose liability on Defendants for stating opinions about Plaintiff’s hateful conduct—such as that she is a “bigot,” or of incontrovertible truth, such as that Plaintiff defended and continues to defend a man found liable for rape. Indeed, in her 310-paragraph complaint, Plaintiff has not identified a single statement by the Church that is neither an opinion nor true.
Plaintiff’s attempt to tortify a public debate—that she initiated and has profited from—is why California enacted its anti-SLAPP statute. It is no surprise that the allegations satisfy both the first and second prong of the anti-SLAPP analysis. Plaintiff cannot deny that, under prong 1, the statements at issue concern a matter of public interest—making them so has been her bread and butter for a decade.
Alleged non-speech conduct—that Plaintiff characterizes as “surveillance”—is pre-litigation petitioning, and thus also protected prong 1 conduct. As to prong 2—whether Plaintiff can prevail on her claims—dozens of the allegations are barred by the applicable statute of limitations. And as to those that are not, they are nonactionable exercises of free speech, such as true statements, statements of opinion, and group boycott. In addition, Plaintiff cannot meet her burden to establish through admissible evidence elements of each of her claims, as she must to survive this motion.
The length of the Complaint belies how little is actually there. When stripped of the allegations that depend on nonactionable statements, protected petitioning, and are outside the statute of limitations, there is virtually nothing left. The anti-SLAPP statute demands that this frontal assault on First Amendment protected speech and conduct be stricken.
The filing then goes into some background, explaining that Leah Remini left the church in 2013. She then began criticizing the church.
Plaintiff then began a campaign to destroy the Church. Through an autobiography, a cable television show called “The Aftermath” (aired on the A&E network for three seasons), podcasts, media interviews, and her own social media accounts of 8.3 million followers Plaintiff has broadcast to the world and interjected herself into a public debate on the following:
- Plaintiff has demonized the entire Scientology religion as “pure fucking evil,” “poison,” a “fraud,” “criminal,” “terrorist,” and “a dangerous vile cult.” “[K]now the difference between somebody having faith and Scientology. They are two completely—they shouldn’t even be in the same fucking sentence.”
- She has falsely claimed that Scientologists are “robot[s],” “extremists,” “manipulators,” “pussies,” “horrible,” “hateful,” and “a bunch of fucking like body snatchers” who are “selling your soul to the devil,” “not mentally sound,” “have zero compassion,” do “not enjoy their lives,” “can’t afford to feed their families,” “can’t think for themselves,” “don’t give a shit,” are “morally depleted,” and have “done nothing good.”
- Despite the Church’s worldwide charitable and humanitarian endeavors, on Plaintiff’s podcast, her co-host, Mike Rinder, said with Plaintiff’s approval that Scientologists “are the people that will fly a plane into the World Trade Center, or blow up a bus in Tel Aviv or whatever with a bomb strapped to them.” Plaintiff has said to the Church and its adherents: “Shut the fuck up. Fucking religion. I’m going to tell you this, you can go fuck yourself. A bunch of fucking body snatchers. Nazi youth. I don’t care what the fuck you say. Don’t give a fuck. If you don’t fucking like it, get the fuck out!”
- Plaintiff has even threatened individual Scientologists: “And listen, you know, I’m gonna say this to you Scientologists in good standing, you should really think about what the fuck you say. Because, you know, well I have information about you too, about your family, and, you know, I have information on all of you. And I could talk about it too.”
The filth and threats go on and on. Plaintiff’s multi-media dehumanization of the Church as “terrorist” and Scientologists as “morally depleted . . . robots” has, predictably, endangered Scientologists throughout the world. To cite just a few acts of violence inspired by Plaintiff’s war of words against Scientology:
- In December 2015, after posting on Facebook, “Leah Remini is a true inspiration!!” Erin McMurtry drove her car through the front door of the Church of Scientology in Austin. When McMurty was arrested and she was told no one was hurt, she replied, “That’s too bad.”
- In April 2016, Brandon Reisdorf sent several threatening emails to Scientologists, stating that Scientology would be “going down” on April 29th and 30th—the date Plaintiff and other anti-Scientologists were interviewed on ABC 20/20. Reisdorf was then arrested for smashing a hammer through a plate glass window of the Church. He also made threats to harm the ecclesiastical leader of the Scientology religion, Mr. Miscavige. After this violent attack, Plaintiff featured Reisdorf on her television show. And after that, Reisdorf was arrested again for violating a restraining order to protect the Church.
- On December 1, 2016, Timothy James Kenney responded to a tweet by Leah Remini: “@LeahRemini @Scientology #ScientologyTheAftermath #Success!!” Kenney then sent a death threat to scientology.org: “You should all kill yourselves. Or come to my neighborhood and let me do it for you.” His Facebook account included photos of his assault rifle.
- On January 12, 2017, Patrick Hebb posted on Facebook that he hoped the Church leader was assassinated and threatened that if any Church member ran into him in the street he would “fuck one of you up!” Hebb added he would “join the fight with Leah Remini and do my very best to end your miserable existence!”
- On January 8, 2020, Donald Myers, a staff photographer for Plaintiff’s television show, was arrested after he entered and refused to leave the Church of Scientology Mission of Los Feliz. Myers screamed at one of the Church staff, kicked a table over hitting the staff member in the leg, and then spat in the face of the staff member. While being arrested, Myers yelled, “I am setting you [the police] up to be o Leah Remini’s show.”
Plaintiff’s The Aftermath television show alone generated hundreds of threats against the Church, including assassination threats against Mr. Miscavige, the ecclesiastical leader of the Scientology religion:
- Sammi Shaw: “If you guys haven’t watched @LeahRemini and @MikeRinder and their brave adventure fighting against @Scientology, called: Leah Remini, Scientology and the Aftermath, you need to watch it so we can come together to destroy this brainwashing cult.”
- Gayspacegem: “leah remini’s AMA about Scientology ……. holy shit” and “hey so who wants to take one for the team and burn all scientology buildings to the ground and salt the earth?”
- Greatdaneaddict: “Holy hell I am crying so hard watching Scientology and the Aftermath. HOLY. HELL.” And “I don’t watch this show that often because it’s emotionally exhausting. I want to burn down every single Scientology building. EVERY. SINGLE. ONE.”
- Pete: “Rewatching episodes of my new fav show #Aftermath and wondering why no one has assassinated Miscavige @LeahRemini just sayin’”
Plaintiff’s hatemongering imperiled the lives of Scientologists worldwide. On January 3, 2019, the inevitable occurred. A 19-year-old man stabbed to death a security guard at a Scientology church in Australia. The assailant had expressed anti-Scientology sentiments. He had accessed on his cell phone an anti-Scientology website with links to Plaintiff’s television show.
In the face of Plaintiff’s blood libel, the Church responded by speaking the truth. It documented Plaintiff’s hateful statements and compiled them on websites, so she could not later deny her own words, including blogs such as “A&E and Leah Remini Spread Hate,” and “Leah Remini’s Real Aftermath: Hate Speech, Threats and Violence.” The Church justly pointed out that Plaintiff is “an unhinged religious bigot who profits by spreading hate.” Acting with STAND, the Church sent letters and posted “open letters” to media platforms and corporate sponsors who gave Plaintiff a megaphone, shaming them for “dehumanizing, hateful content”, “promoting hate”, “sponsoring hate”, and for doing business with “an unhinged religious bigot who profits by spreading hate”, who engages “in obscenity-laced and abusive language, to insult, defame and demean Scientologists.”
The Church documented that Plaintiff’s show was a “Total Fraud” because guests repeatedly misrepresented their experiences within Scientology . Defendants also supported their “fraud” interpretation of Plaintiff’s show by demonstrating that it misrepresented the beliefs of the Scientology religion, consisted of scripted interviews, was co-hosted by Mike Rinder (an admitted liar and domestic abuser), was cast with other criminals and documented liars, and was knee-deep in payola for guests who appeared with their “stories” about the Church. The Church also showed that Game Show Network—Plaintiff’s employer after A&E—had no standards for airing Plaintiff’s bigotry: “What’s next? A game show ‘hosted’ by a KKK leader? Neo-Nazi Jeopardy?”
Defendants showed to the world that Plaintiff’s air of moral superiority bore within it the stench of hypocrisy. This included STAND publishing the article, “Game Show Network Employs a Rape Apologist as Their Host?” (pointing out Plaintiff’s undisputed support for (1) Paul Haggis, who was found liable for $10 million in a civil rape case where Plaintiff testified in his defense, and (2) Les Moonves, the disgraced former head of CBS, exiled after an investigation into his sexual predation).)
Websites also featured interviews with Plaintiff’s former employees speaking of her abusive behavior, interviews with her family speaking of how she abandoned them and welched on promises to pay for cancer treatment (id., Ex. 60), and a friend recounting Plaintiff’s use of “niglet” to refer to the friend’s African-American children.
Plaintiff’s own ugly speech led to her demise as platforms and sponsors fled her toxic brand. She has now attacked the Church and filed this lawsuit. She tellingly does not deny any of the bigoted, obscenity-laced statements attributed to her, that her followers have committed crimes in her name, or even that she is a defender of rapist Paul Haggis. Rather, she is suing because the Church has pointed this all out and has made fair comment on these statements, such as that she is a “bigot,” does “spread hate,” and, indeed, has “apologized” for a “rapist.” It is hard to imagine that any case has come to this Court or any other court in California that more offends the First Amendment and is more deserving of dismissal under the anti-SLAPP statute.
The filing then goes into legal arguments, and then has even more sections going into more detail about specific things said about Remini by the church, and things said about the church by Remini. We’ll let you go through the entire document yourself to find those.
(They’ve also attached more than 1,000 pages of exhibits to go with this filing, including lots of examples from Marty Rathbun’s videos, the STAND website, and Scientology’s websites dedicated to Remini and her TV show.)
Well, this is the big blast from the church we were expecting. And they certainly don’t disappoint. Expose Scientology for its abuses, and they come back at you just as hard. But how will a court see it?
The defendants are asking the court to consider this motion to strike at a hearing on November 28. Before that, the only thing scheduled is a hearing on November 17 to consider allowing Leah’s out-of-town attorneys to join the case.
Wow. Battle has really begun.
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Did the $cieno lawyers just take responsibility for all of the 'anti-Remini' web sites?? They make the suit sound like Cartman and Kyle Browsloski in the 3rd grade school yard.
It’s a whale and we’re here for it.