The civil case against Scientology and Danny Masterson, laid out in detail

Last month, we told you that the lawsuit filed by Danny Masterson’s victims was about to go through some big changes. The Jane Does suing Masterson and Scientology had submitted a new proposed version of the lawsuit that would add another plaintiff (actress Tricia Vessey), and also add sexual battery allegations against Masterson as well as civil RICO counts as they seek to prove that Scientology is a criminal enterprise.

It’s exciting stuff, but while we wait to see whether Judge Upinder Kalra will allow the new complaint, there is still the matter of the motion to strike that Scientology filed to remove significant portions of the previous version of the lawsuit, which dates back to 2020.

The Jane Does are opposing that motion to strike, and there’s a hearing scheduled for February 13 to argue the matter. In anticipation of that, the Jane Does and their legal team have submitted oppositions to Scientology’s motion, and the individual women have also submitted very interesting declarations spelling out their allegations against Masterson and Scientology.

Who better than the victims themselves to explain this case, right? And to detail the kinds of harassment that they have been going through since they came forward to the LAPD.

Here then is the declaration of Jane Doe #1, which we figured you’d want to see in its entirety. Imagine a jury getting to hear this stuff.

 
DECLARATION OF JANE DOE #1

I, Jane Doe #1, declare as follows:

1. I am over the age of eighteen (18). I have personal knowledge of the facts stated below and, if called upon to do so, could and would competently testify thereto.

2. I am a Plaintiff in the case of Bixler, et al. v. Church of Scientology International, Inc., et al.

3. I submit this Declaration in Support of Plaintiffs’ Opposition to Defendants’ Special Motion to Strike Certain Allegations and Corresponding Causes of Action from the First Amended Complaint of Plaintiff Jane Doe #1 (“Motion”).

4. I was raised in Scientology by my parents and became a member of the Sea Org when I was 17 years old.

5. I met Daniel Masterson in 1999-2000 as he was acquainted with my father. My close friend, Brie Shaffer, was employed as Masterson’s personal assistant.

6. I would see Masterson often at social gatherings due to our mutual friends, but we were not friends.

7. At these social gatherings, Masterson would make sexual advances towards me and then berated me for refusing his advances.

8. In September 2002, I was supposed to meet with a group that included Shaffer, Masterson, and others.

9. After I arrived, I learned that Shaffer was not coming.

10. I encountered Masterson, who had already purchased a drink for me and encouraged me to drink it.

11. After I finished the drink, Masterson immediately ordered another drink for me.

12. As I began to consume the second drink, I felt the effects of the alcohol.

13. The effects felt were greater than I expected after having consumed similar amounts of alcohol in the past.

14. I was supposed to stay at Shaffer’s house but due to her absence, Shaffer had arranged for me to stay in Masterson’s guest room.

15. I realized that I was intoxicated and went to bed alone in the guest room.

16. I awoke to Masterson having sex with me.

17. I was intoxicated to the extent I could not consent to this sexual encounter.

18. I was confused, disoriented, scared, and intoxicated to the point where I could not defend myself or resist.

19. Eventually, I was able to push Masterson off of me.

20. I did not want to have sex with Masterson and did not consent to any sexual encounter.

21. I tried to avoid being alone with Masterson.

22. On or about April 24-25, 2003, I was present at Masterson’s home along with multiple other people. Most people were in Masterson’s backyard drinking and using a Jacuzzi tub.

23. Masterson made me a drink, and as I drank it I began to feel very sick and disoriented.

24. I became far more intoxicated than I had been previously when drinking the same amount of alcohol. I thought that I must have been drugged.

25. Masterson forcefully pulled me out of the chair I was sitting in and pushed me into the Jacuzzi tub.

26. When I got out of the Jacuzzi tub, I began to feel worse. I could not open my eyes and was having difficulty breathing.

27. Masterson said he would take me inside to throw up. I said I did not want to go with him and his close friend, Luke Watson, said he would take care of me.

28. Watson is the son of Susan Watson, President of Defendant Celebrity Centre International. Masterson insisted that he take me and proceeded to pick me up.

29. I protested as Masterson tried to carry me upstairs.

30. I was disoriented and unable to stand on my own. Masterson put me in front of the toilet and stuck his fingers down my throat to induce vomiting. He then undressed me and put me in the shower where he handled me very aggressively and sexually assaulted me. I was intermittently unconscious. Masterson then dragged me from the shower and threw me onto his bed where I passed out.

31. I awoke to Defendant Masterson raping me. I attempted to fight him off by shoving a pillow into his face, but he pushed it back down onto my face, making it difficult for me to breathe. Masterson also used his hands to strangle me until I lost consciousness.

32. During the rape, when I heard noise coming from the other side of the bedroom door, Masterson told me not to say a word and reached into a drawer and picked up a gun.

33. Defendant Masterson then held me down and anally assaulted me. Masterson only stopped when he heard a voice at the bedroom door and went to investigate.

34. I recall at one point, I escaped from the bedroom and returned downstairs. I recall Defendant Masterson and Watson grabbing me and bringing me back up to Masterson’s bedroom.

35. I recall crawling into the bedroom closet and passing out. I woke up the next morning naked and hiding in the closet.

36. Masterson’s sexual assault was reported to Defendant Church of Scientology Celebrity Center International by someone other than me.

37. My friend D.P. later told me that he saw Masterson push me into the jacuzzi and then take me upstairs. He said that he saw me approximately about an hour and a half later when I came up to him with wet hair and bare feet and said, “Oh my God Danny just raped me.” D.P. also observed Masterson and Watson trying to get me back upstairs.

38. D.P., who was a Scientologist at the time, also told me that he was called into the Church of Scientology Celebrity Centre within days of the sexual assault. He was confronted by an agent of Defendants, CCI Ethics Officer Miranda Scoggins, and told “in no uncertain terms” that Masterson “had not done anything” to me. He was told that I was “doing ethics handlings” to help me. D.P., tried to do as he was told but would remain haunted by what he saw for years until he became the connection between me and Plaintiff Bixler.

39. In May of 2003, I reported Masterson’s assault to my Ethics Officer, Julian Swartz.

40. Swartz is an Ethics Officer to many celebrities and other prominent Scientologists and as a result he consistently communicates with the highest levels of Defendant CSI.

41. I reported to Swartz what I recalled at the time about what Masterson had done. I also reported that I had told a friend, Swartz instructed me to go back to my friend and tell him what I said about Masterson was not true and that I was joking. Swartz also told me not to speak about it to anyone and that it would be handled internally within Scientology. I attempted to explain to Swarts that what happened was rape. This infuriated Swartz who insisted that this was not rape and that I was “not to use the ‘R’ word again.”

42. Defendant CSI required me to begin an ethics program that Swartz designed. It required that I report to him daily and get his permission to travel. It required me to read many policies, including those policies that state it is a “high crime” to report anything criminal or negative about another Scientologist, policies regarding disconnection, policies regarding how one becomes declared Suppressive Person, and policies that describe what happens to Suppressive Persons. Swartz consistently reminded me not to talk about the sexual assault and repeatedly told me that high ranking officials within CSI were aware of my ethics programming and monitoring it closely.

43. The ethics program designed by Swartz also included frequent and hours-long auditing sessions in which I was repeatedly asked to admit to “past crimes” that I allegedly committed during previous lifetimes. I was pressured into “confessing” to “evil purposes” I had toward Miscavige, Scientology, L. Ron Hubbard, and others.

44. In July 2003, I encountered Watson, who admitted that he reported the sexual assault directly to Defendant Miscavige.

45. In December of 2003, the Institutional Defendants and/or Defendant Masterson discovered that I had told friends and family about the sexual assault. I was first ordered to meet with Miranda Scoggins and then Swartz. I was handed a “non-enturbulation order,” a formal censure that precedes a Scientologist being declared a suppressive person. I was told that if I continued to talk about the assault, I would instantly be declared a suppressive person and would be subject to Fair Game.

46. In January 2004, I was made to undergo “security checks” or “sec checks” which are used by the Institutional Defendants and/or Defendant Masterson as a form of investigation. I was subjected to intense auditing that included reading reports written about the sexual assault, including those written by Watson and Masterson. Defendant Masterson’s report included admissions about the sexual assault. Despite Defendant Masterson’s and Watson’s admissions, the Institutional Defendants and Defendant Miscavige never took negative action against Defendant Masterson.

47. At the conclusion of this “sec check,” I was forced to sit in a room alone with Masterson, the man who sexually assaulted me, at the direction of the Institutional Defendants and/or Defendant Masterson so that we could “clear the air.”

48. In January 2004, my mother, who is a Scientologist, wrote a letter to Tammy Wilkoff, an official with Defendant RTC. In it, she detailed the sexual assaults committed against me and the woefully inadequate response from the Institutional Defendants. She detailed a number of disturbing reports written about the assault and how Defendants CSI and/or CCI was failing to address it. She also wrote that she believed the non-enturbulation order entered against me was intended to suppress information related to my assault from being made known. She also related that she learned Shaffer had written a report concerning the sexual assault to the Institutional Defendants the day after it occurred.

49. In March 2004, frustrated with the lack of progress after her January 2004 letter, my mother wrote another letter, this time directly to Defendant Miscavige. She attached her January 2004 letter and demanded that Miscavige act. She detailed admissions by Masterson and Watson, as well as inconsistencies in their account of what had occurred.

50. In response to these letters the non-enturbulation order against me was lifted and I was given free auditing by the Institutional Defendants.

51. I received a letter on April 21, 2004, from Defendant CSI International Justice Chief Mike Ellis reminding me of the written policy in Scientology that it is a “Suppressive Act” to report a fellow Scientologist in good standing to civil authorities.

52. On June 6, 2004, despite more than a year of institutional Defendants and their agents trying to convince me to not report that I was not raped, included convincing D.P., a critical witness to a criminal prosecution, that nothing wrong or criminal had occurred. I reported the sexual assault to the Los Angeles Police Department. The Institutional Defendants and Defendant Masterson mobilized against me to ensure no charges were filed.

53. Charges against Masterson were not filed.

54. After my report to LAPD, Kendrick Moxon, a partner from Moxon and Bowles, the law firm that represents the interests of the Institutional Defendants and its affiliate organizations, arrived at my parents’ home and met with my father. Moxon handed me a letter instructed me to step outside and read it while he had a private conversation with my father. Moxon was acting as an agent of the Institutional Defendants and/or Masterson. The attorney carried with him a letter, written by Defendant Masterson, where he stated words to the effect of “if you got hurt, sorry you got hurt.” I was astonished that this is how Masterson attempted to apologize for raping me. I was told that I was not allowed to keep the letter. Moxon advised my father that Swartz would be contacting me to broker a meeting between me and an attorney for Masterson, which Swartz did.

55. Ultimately, I was instructed to go to Singer’s office where I was presented a document to sign. Singer was acting as an agent of Masterson and/or the Institutional Defendants. I was told that unless I signed a non-disclosure agreement that included Masterson and the Institutional Defendants, that I would be declared a SP and my family would be forced to disconnect from me. As a result, and with no other choice, I signed the document that was put to me. I was not given a copy of the document.

56. In or around June 2005, I was told by someone I knew to be a Scientologist that I had been declared. I was shocked since I had signed the non-disclosure agreement, albeit under duress and coercion, and believed that I would not be declared as a result of signing the non-disclosure agreement.

57. Around the Father’s Day 2005, I arrived in Florida with my family and attempted to enter Scientologist Flag Land Base, and I was informed that I was not allowed to enter the Org because I had been declared. Despite protestations from my family I was refused entry onto the Org because I had been declared a SP. I left Florida and returned to California.

58. In 2016, I learned that Plaintiff Bixler was seeking to contact me. I connected with Plaintiff Bixler and eventually confided that I had been assaulted by Masterson. Subsequently, I was contacted in December 2016 by the Los Angeles Police Department regarding my previously reported sexual assault.

59. As a result of reporting my sexual assault to the police, I was declared a “suppressive person” by the Institutional Defendants and/or Masterson.

60. After I was contacted by the police in 2016, Defendants carried out an intense fair game campaign against me. Thereafter, as previously threatened, Defendants launched a campaign of harassment, surveillance, and abuse against me and my family which continues today.

61. Upon information and belief, all the following-described acts of harassment, surveillance, and/or stalking were carried out by or at the direction of Defendants’ employees, agents, and/or representatives.

62. From late 2016 to present, I have received hundreds of phone calls and texts messages from unknown numbers.

63. On one occasion in 2018, I answered my phone and a man’s voice asked if I was “scared” before the call was quickly terminated. This call came from a number with a New York area code that repeatedly called my phone number. I reported this latest incident to the LAPD and was advised detective with the LAPD called the number; I never received a phone call from that New York number again.

64. In November of 2016, I was followed and surveilled by Defendants’ agent Michelle Miskovich. Miskovich followed me to a Best Buy and proceeded to follow me into the store. After this instance, Miskovich contacted a reporter to claim that I and other Plaintiffs were fabricating our claims against Masterson. Several months later, Miskovich contacted B.S., a witness to my sexual assault, in an attempt to dissuade B.S. from speaking with police.

65. Defendants had others attempt to dissuade B.S. from telling the truth. For instance, Vanessa Mooney, who told B.S. that I was fabricating my claims against Masterson.

66. I was contacted by Masterson’s publicist, Jenni Weinman, after Weinman contacted Plaintiff Bixler. Weinman is an agent of Defendant Masterson. Weinman pretended not to know me despite the fact that we met previously, socialized together, and I was present with her on one of the occasions that I was sexually assaulted by Masterson. I was advised by Plaintiff Bixler that Weinman told Plaintiff Bixler that she knew me. Weinman attempted to gather information from me about the sexual assaults committed by Masterson against me. Weinman also encouraged me not to pursue my allegations any further.

67. I observed an SUV sitting outside of my home on many occasions for long periods of time. I observed the driver of the SUV, an agents of Defendants, photographing me with his cell phone.

68. In March of 2017, a blog was posted online publicly revealing the existence of an LAPD investigation into Defendant Masterson as a result of the reports of sexual abuse.

69. In March or April 2017, I was followed by Shaffer, Masterson’s one-time personal assistant, throughout Larchmont Village for approximately twenty minutes.

70. In March and April of 2017, my mother, a Scientologist, had frequent phone contact with me. In one call she told me that I was already under surveillance. She later told me that I should be prepared to be followed and have my trash taken. My mother repeatedly told me, through at least 2019, that I should “keep my trash clean.” My trash has in fact been frequently stolen and I repeatedly observed people following me on many occasions. When I complained via text about being stalked, harassed, followed, and having my trash taken, my mother suggested that Defendant Masterson and/or his associates were responsible.

71. Around this time, my mother advised me to “leave the past in the past,” warned me not to end up like my father (who passed away years earlier), and warned me against getting trapped into scorching the earth and that it would only lead to my death and sorrow.

72. My mother has been provided legal counsel by the Institutional Defendants for purposes of the criminal investigation. My mother has not been fully cooperative with law enforcement. Furthermore, I was told by Scott Ross, a private investigator for Defendant Masterson’s attorney Thomas Mesereau, that any Scientologist he wishes to speak to must be contacted through attorneys for the Church, whether they are represented by those attorneys or not.

73. I retained an attorney to attempt to obtain a copy of the non-disclosure agreement I signed under duress and coercion. That attorney contacted Marty Singer, who still represents Defendant Masterson. Singer informed my counsel that I was violating the terms of the agreement and that I could not have a copy as “only the lawyers” got copies if they also entered into a million-dollar non-disclosure agreement. My attorney refused.

74. In March of 2017, I observed my card doors open and found that my car was broken into in front of my home and a debit card was stolen. The account linked to those cards was then over-drafted in the middle of the night.

75. On many occasions, I observed my trash being dumped into the back of a vehicle.

76. In April of 2017, I noticed I was frequently being followed.

77. In 2018, I frequently awoke to find my car door(s) open.

78. Beginning in March 2018, I observed people frequently parked outside my family home for hours and looking into my windows. On one occasion, I confronted an agent of the Defendants, a woman who was surveilling my home. The woman wore all black and baggy clothes including a hoodie. Beginning in May 2018, the woman would stand outside the curtilage of my home after midnight and stare at the property. The woman also rifled through my trash. On certain evenings, the woman used a flashlight and pointed the beam into various windows of the home including my children’s bedrooms. The woman also followed me in public during the day including to my hair salon. I contacted LAPD who ultimately identified the woman and approached her in the vicinity of my residence. at that time the woman provided a fake name to LAPD. During the summer of 2018, I went on an extended vacation and was advised that the woman no longer stood outside my house. When I returned, so did the woman. LAPD then confronted the woman at her own residence. The woman continued to return to my home where she made obscene gestures in the direction of my home and continued to flash a beam at and inside my home.

79. In and around September of 2018, Defendants’ agent Kathy Gold started publicly threatening Masterson’s victims, including me. Her blog on WordPress stated that she would kill them and claim self-defense. I sent the blog post to the LAPD. A true and correct copy of one of Gold’s threats against me and other Plaintiffs is attached as Exhibit A.

80. In January of 2019, I was at an appointment with an accountant. When I left the appointment and was walking to my car, I was accosted by two agents of the Defendants, a male and a female. They were yelling at me and threatening my life. The male spat on my windshield as I fled the parking lot. I later found out that a major tenant who shares the building with my accountant is a company run by a Scientologist. I was able to use the company website to identify the two individuals that accosted me and threatened my life. Both are Scientologists. In addition, one of the individuals that works at the company is a friend of Masterson and gave a statement in favor of Masterson during the course of the criminal investigation.

81. In February of 2019, I was followed into and around a grocery store by a man in a Sea Org uniform. Thirty minutes later when I got into my car the maps application on my phone suggested that I drive to an address around the corner from my home. This continued to occur for the following several months.

82. In March of 2019, I observed that the home adjacent to the rear of my property trimmed back a tree that had secluded my home, leaving my home visible to the neighboring property. Around this time, my cell phone map application would frequently malfunction and redirect me to that neighboring property instead of my own home. Additionally, my husband observed a man in our backyard. When my husband confronted him, the man fled back to the neighboring property. I later discovered that the property is owned by Scientologists, and their son, a Sea Org member, resides at that property.

83. Starting in March 2019, immediately after the man described in preceding paragraph was on my property, a tree that partially obstructed the view of my home from the neighboring property began to die. In April 2019 I consulted with a gardener who informed me the tree had been poisoned at the root. In June 2019, it was confirmed that the tree was poisoned and the dead portions of the tree were cut down. My property can now easily be seen from my neighbor’s property, the home owned and occupied by Scientologists.

84. There have been three occasions when I was in a specific hardware store when I was followed by different men in Sea Org uniforms. On one of these occasions, the man photographed me in the store.

85. I have also experienced various acts of fraud committed against me including prescription fraud.

86. On multiple occasions, agents of Defendants have approached my residence pretending to be solicitors and have made efforts to gain access to my home.

87. I also experienced a host of issues with technology outside of that detailed above including but not limited to having my cellular devices connect to other devices that I do not own and have never heard of as well as hearing voices, noises, and other interference in the background of phone calls made from my cellular devices.

88. In August 2021, an investigator with the Los Angeles District Attorney’s, first name “Lou,” came to my home to evaluate my home security and electronic devises and advised that our home and our devises had been compromised and gave me specific instructions on how to lock down our home security and devises.

89. To this day, I continue to be threatened, harassed, stalked, and surveilled.

90. In or around June 2023, shortly after Defendant Masterson was convicted, a known agent of Scientology tweeted about me and the other Plaintiffs:

Because those 3 women implied drug use by Masterson, every Scientologist in LA now knows they were lying. Scientologist just don’t use drugs. Every Scientologist who recognizes these women will spit on them, for the rest of their lives. I sure wouldn’t want to be them.

A true and correct copy of this tweet is attached hereto as Exhibit B.

91. Later that day, the same known agent of Scientology tweeted:

Since these women live in LA and there are thousands of Scientologists in every walk of life in LA, the three women who lied in the Danny Masterson case will get spit on a lot. I don’t think they will take it out on the jury or judge since these were just fooled and manipulated by a false “expert witness.” But the 4 women will live in hell, now and for the rest of their lives.

A true and correct copy of this tweet is attached hereto as Exhibit C.

92. These actions described above were committed by Defendants, their agents, employees and/or representatives.

93. The Corporate Defendants did not report the abuse to any governmental authorities, nor did they take any other action to protect women from future harm by Defendant Masterson.

94. Thereafter, as previously threatened, Defendants launched a campaign of harassment, surveillance, and abuse against me and my family which continues today.

95. As a result of the foregoing, I continue to be in fear for my life and the safety of my family. I am always looking over my shoulder and worried that someone is following me or will harass me. I am very worried for my children’s safety and well-being. I have difficulty sleeping. I am always anxious. I have two service dogs who provide me a sense of security and alert me and assist me when I have a panic attack. I have been prescribed anti-anxiety medications. The simplest things can cause me extreme fear — a car driving by or a person walking up behind me on a street. I do not feel safe.

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

Executed on this 8th day of January, 2024, at Los Angeles, California.

Jane Doe #1

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