The Expert: Full affidavit by psychologist called to Scientology's Clearwater arbitration
Yesterday the dam burst and we finally got access to a large amount of information about what’s been going on in the labor-trafficking lawsuit filed against Scientology in Tampa federal court.
The plaintiffs, former Sea Org employees and Australia residents Valeska Paris and Gawain and Laura Baxter, sued in 2022 over allegations that they had been trafficked as virtual slaves aboard Scientology’s cruise ship the Freewinds as children and adults. But federal Judge Thomas Barber said his hands were tied by US Supreme Court precedent and he had no choice but to force the case into Scientology’s “religious arbitration.”
Valeska and the Baxters went through 15 days of arbitration in Clearwater that began on January 19 before walking out. They are now asking Judge Barber to consider a motion to reconsider, complaining that Scientology has harassed and intimidated them during its sham of an arbitration.
Yesterday we reviewed the basic points of that motion and then posted Valeska’s full declaration about what those 15 days were like.
During that period, Scientology called more than 30 witnesses to testify. Valeska and the Baxters called only one: A New York psychologist, Dr. Chitra Raghavan. (Valeska explained that Dr. Raghavan was their only witness who could make the trip to Clearwater.)
Although she was only in the proceeding for a single day, Dr. Raghavan provided some very interesting observations about what went on in that chamber, where even the attorneys on both sides were not given access. Here is her declaration in full.
I, Dr. Chitra Raghavan, declare as follows:
1. I am a licensed psychologist and was retained as an expert in this matter. I submit this declaration based on my personal knowledge and observations.
2. On January 28, 2026, I appeared at a Scientology arbitration proceeding in the Baxter et. al. v. Miscavige et. al. 8:22-cv-00986-TPB-JSS matter. I appeared as an expert witness for the claimants.
3. At the onset of the meeting, I signed an NDA. I verbally informed Scientology that while I would not discuss the arbitration publicly, I would fully communicate with the Claimants’ lawyers and the courts as appropriate.
4. Because the Claimants’ lawyers were not present, I could not have them review the language of the NDA. I therefore signed reluctantly in order for the proceeding to continue while insisting that the NDA did not preclude communications such as this.
5. I have testified in 42 Federal and State Court trials between 2016-2025.
6. The Scientology arbitration was unlike any proceeding in which I have previously testified. In sum, the composition of the members, the nature of questions asked, and the requirement that I conduct my own testimony and redirect were unusual and in some moments, unprofessional.
7. While I have appeared in court many times and have been aggressively cross-examined, such proceedings were always under the watch of a neutral judge and or counsel. When opposing counsel overstepped bounds, a judge or the lawyers have objected and successfully brought the proceeding to a professional tone. This was not a possibility in this arbitration.
8. I appeared in the arbitration from approximately 11:00 am to 5:15 pm with three breaks, including a lunch break.
9. During my appearance, there were eleven individuals in the arbitration room: four representatives, one for each of the Scientology entity Respondents; three arbitrators; three Claimants, and I.
10. The Claimants were outnumbered. To the best of my opinion — and later confirmed verbally spontaneously by the Claimants — the Claimants appeared highly distressed throughout the proceeding. They were repeatedly denied the opportunity to present their perspective, which appeared to be frustrating and stressful for them and verbally expressed their frustration several times to be so to the panel. For example, the Claimants were not permitted to provide context about the photos that were shown to me until I insisted that they be allowed to provide at least one line statements about the photographs. They were berated several times for speaking without permission and became visibly dysregulated. One Claimant was visibly trembling. In my professional opinion to a reasonable degree of psychological certainty, the conduct of the arbitration panel would have made any reasonable person feel intimidated and anxious. In fact, I myself had moments of intimidation despite my position and experience. Given their trauma history, the procedure itself was especially difficult for the Claimants, which in my professional opinion increased their trauma responses in the moment, leaving them feeling frightened and unprotected.
11. The fear, anxiety, and stress the Claimants appeared to be experiencing during the proceedings was visible and obvious. Claimants spontaneously revealed throughout the breaks that they felt anxious, unsafe, and that the breaks were reassuring so they could regather their energy.
12. Claimants’ attorneys were present in the building, but they were not permitted to attend or participate in the arbitration.
13. As a result, I did not have an attorney present to object to hearsay, lack of foundation, or improper questioning. I was required to raise my own objections, conduct my own redirect, and explain repeatedly why I could not respond to certain questions. For example, I am not an attorney and cannot opine on contracts. Similarly, the Claimants, do not have the skills or knowledge required to make appropriate objections.
14. One arbitrator, the panel Chair, Ms. Fraser, spoke extensively and appeared to control the questioning, Another arbitrator, Mr. Howd, interjected occasionally and the third arbitrator, Ms. Van Locke, did not speak at all during the proceeding. I understand that the silent, third arbitrator, was the arbitrator selected by the Claimants.
15. Two of the Respondents questioned me directly, though most of the questioning came from Ms. Fraser. At the end, a male Respondent posed a question and used a tone of voice and facial expression that conveyed hostility and what I experienced as contempt for me. The arbitration Chair did nothing to control his behavior. The Respondents’ hostility — while not necessarily dissimilar to aggressive court room questioning — left me shaken because the setup and atmosphere was inherently intimidating.
16. The arbitration panel appeared not to understand my role as an expert in these proceedings. The panel insisted that I make factual and legal determinations that are inappropriate for an expert, and outside the scope of my expertise. When I refused, they repeated the question over and over to obtain an answer. I was not permitted to explain or stop the inappropriate questions (which a judge or lawyer likely would have). As a result, the questioning felt pressuring and uncomfortable.
17. Witnesses were not sworn, and Ms. Fraser asked me to make immediate judgments based on unsworn statements and previously undisclosed evidence that I had not had the opportunity to review. While testifying, I was not given an adequate amount of time to review the materials.
18. The panel Chair read aloud extensive testimony from unnamed witnesses. I was then asked whether, having now heard from so many witnesses, I would change my opinion. I explained that I had not met, interviewed, or evaluated these individuals and that relying on such second-hand testimony does not meet psychological standards of expertise or methodology.
19. The panel also insisted on showing me 800 photos and videos of the Claimants, and I was asked to comment on them. These materials had not been produced in discovery, and therefore I had not had an opportunity to review them meaningfully independently or to obtain any contextual information from the Claimants. When I requested that the panel stop showing me the volumes of photos (because the photos did not add to data in meaningful way), Ms. Fraser said she were unable to stop and spent over an hour, possibly two, repeatedly asking me if the photographs depicted the Claimants as happy individuals, therefore negating allegations of harm. I repeatedly explained why I could not opine on this.
20. The Claimants were not provided access to these materials either. I explained that without proper access and context, I could not responsibly comment on or draw conclusions from such materials.
21. The Claimants were distressed by the photographs and commented that the contexts were not provided, leading to potential misinterpretation of the images. The Claimants also expressed distress that they could not defend or explain the contexts of the images; one Claimant was upset because although these were his childhood photos, his parent who remains in Scientology has never given him access to the photos.
22. I did not see evidence of the panel allowing the Claimants to provide their point of view. These sorts of experiences suggested that the procedure was biased or at the very least, flawed.
23. The panel also showed me approximately 20 letters and “success stories,” including documents written by the Claimants when they minors, and gave me approximately 30 seconds to review each document. The Claimants were children when they wrote the letters and stories, but the language in the documents appeared developmentally incongruent with the age of the author suggesting scripting and coaching. I stated that I would need additional time and context, including the Claimants’ explanations, to evaluate such materials responsibly.
24. When I asked about whether a Scientologist minor could disagree with teaching materials or objectives, the Chair explained that they could not; therefore, the only successful outcome was to write an essay describing how much they had benefited from the class. Writing any other essay would mandatorily return the student to retake the class. One of the Claimants recalled verbally during the proceeding how he had written the letter under duress, desperate to avoid retaking the class which broke him down. It is this kind of context that needs to be available to the fact finder.
25. The Claimants attempted to clarify factual inaccuracies or provide context of photos, videos, and letters, but were told to not speak unless allowed. The panel told Claimants that they could ask questions later, yet they were ultimately not permitted to do so.
26. Eventually, after many requests by the Claimants, I interceded. I asked the panel to permit the Claimants to provide some context and the panel permitted them to give a one-line clarification or rebuttal to each photo if relevant. However, with hundreds of photos (Scientology informed me that they had secured 800 photos), this procedure was chaotic. As best as they could, Claimants tried to explain the context of photos including that they looked so happy because they had not left the ship in a month, or that they were overjoyed to reconnect with friends for two hours after weeks of isolation, etc. In a properly run arbitration, the expert psychologist should not have to intercede on behalf of increasingly distressed Claimants. When Claimants did intercede, they could only hurriedly utter a sentence here or there, before the image vanished, and or, the arbitrator spoke over them. There was constant competition for time.
27. The process felt biased, unprofessional and clinically, I observed that it humiliated and intimidated the Claimants who had to scramble to process the photos as best as they could. Further, it appeared to retraumatize Claimants. Being shown 800 photos in quick succession of a past many Claimants allege is linked to abuse and not being allowed to explain, process, or access the photos was unhelpful to their mental distress. Claimants expressed to me that after that seeing the images but more so, being forced to listen to the panel insist that these were accurate reflections of pleasant experiences felt like bullying and gaslighting. One Claimant noted that she felt like she was back and trapped in Scientology and being forced to agree or be punished. While I do not know if the photos represented a time of happiness, a time of abuse, or both, what is more important here is that the procedure was unprofessional and potentially damaging with no real observable benefits towards discovery. I have observed many videos and painful photographs with other plaintiffs in the course of my forensic work. Some of these images/videos were humiliating, others violent or distressing including happy pictures with an abuser, videos of violent abuse, sexual assault, crime scenes of crimes they had committed, and other distressing images. Through all of this discovery, attorneys and evaluators plan for how to show these images, prepare their clients to view them, and most importantly, explained to clients why they had to view videos/images and allowed plenty of space and opportunity for clients to reject the experience or respond in the way they felt best represented their experiences in those images.
28. The Panel permitted the Respondents to speak any time they had something to say. However, it is my opinion that when they did, there was little procedural professionalism including acknowledging their statements and or questions to obtain more in-depth information. Indeed, from all the questions I heard, it appeared to me that the Panel was either disinterested in the possibility that former Scientologists may have suffered abuse. Instead, the panel presented “Data” and framed questions as if they had already decided that the allegations of abuse and associated harm were false or misinterpretations, and attacked the Claimants narratives, statements, opinions, and experiences. Rather than acting as unbiased arbitrators, I experienced the Panel as an adversarial party as one might in court.
29. This procedure was inconsistent with professional standards, and inconsistent with the procedures I am familiar with from prior trials. Further, the Claimants could not effectively represent themselves and even when they tried, their responses were not acknowledged. These elements further suggested to me that the process was not unbiased as an arbitration should be.
30. I repeatedly explained that I do not opine on facts or make credibility determinations reserved for the trier of fact. I have not and do not intend to offer an opinion on whether or not the alleged abuse occurred but only that the psychological harm I assessed is consistent with the reported abuse. Nonetheless, the arbitrators repeatedly asked me questions outside the scope of my report and outside my expertise.
31. The Panel Chair asked me to spend a significant amount of time reviewing and discussing contracts and I was pressured to agree with the proposition that because the Claimants agreed to participate in Scientology, they therefore could not claim harm. I explained that I cannot opine on the legal meaning or enforceability of contracts, nor on legal consent, as those are legal determinations outside my role as a psychologist.
32. When I refused, they argued that as this was a religious arbitration, the procedures were different and the same rules did not apply. This placed me in the difficult position of either declining to answer, thereby appearing uncooperative, or overstepping my professional boundaries as a psychologist. For example, I was asked questions about legal standards which I consistently refused to answer. However, after being asked the same question over fifteen times, I noticed that I started answering out of exhaustion and feeling harassed. For example, when repeatedly asked if the Claimants had signed a contract, and then asked to read the contract, particularly sections which specified unconditional acceptance of Scientology treatment, I began to answer “it appears so” after over ten or fifteen times of being asked the same question. In a court of law, this would not have been allowed to happen, or at least, in my experience, has never happened.
33. Shortly after I answered, a Claimant exclaimed that she had signed a contract at age six, a fact that had not been disclosed to me earlier.
34. Similarly, the Panel chair also asked me about the Headley case and asked me to read portions of a legal opinion during the proceeding. Considerable time was spent on this. I was then questioned on it and was demanded to agree publicly that the opinion was favorable to Scientology. Similarly, I refused to opine on legal matters. The questioning continued for some time with the same question being repeated. I refused to answer either way, as I was retained as an expert psychologist and am not an attorney.
35. Ms. Fraser also questioned me extensively about the work of Margaret Singer and a 1987 American Psychological Association (“APA”) report on coercive persuasion. I explained that my work concerns coercive control, which is distinct from coercive persuasion, though they may share some elements. I was asked to read portions of the APA report without being given adequate time to review it and was asked to accept characterizations of the report that I did not agree with. I noted that coercive control is recognized in the United Kingdom and is an established area of expertise in domestic violence and child custody contexts in the United States, and that professional understanding evolves over time. I was asked to opine on hypotheticals comparing religious practices such as Catholic communion to coercion.
36. Although I was at the proceeding for a full day, much of Ms. Fraser’s questioning was outside the scope of my report and expertise. Overall, much of the questioning was to request that I agree that the Claimants had voluntarily engaged in Scientology via contracts, was presented with unnamed witnesses who testified that the Claimants enjoyed their experience, and therefore their claims of abuse could not be credible. This is not in the scope of an expert.
37. In my opinion, the lack of basic procedural protections, inability to present or contextualize evidence, and pressure placed on myself as an expert to exceed professional boundaries compromised the fairness of the proceeding. It also created an unsafe and intimidating atmosphere rather than a fair and unbiased one.
38. I have been cross-examined many times. Ms. Fraser’s questioning—while mostly polite and calm—was bordering on nonsensical. Ms. Fraser did lose her temper a few times. At one point, I felt nervous for my physical safety. My fears are subjective but in all my years of being “grilled” in open court, I have never felt fear because I knew I had witnesses, court officers, a judge, and attorneys in the courtroom with me. Finally, I have certainly never experienced any questioning approaching this level of bias or poorly defined scope from a nominally neutral third-party like a judge or presumably an unbiased arbitrator.
39. I was left with the impression that the Panel had no idea of how nor any intention of taking my professional opinions into account in arriving at its decision. But even if it intended to consider my professional opinion, the Panel did not give me an opportunity to properly present it.
40. I declare under penalty of perjury that the foregoing is true and correct.
— Dr. Chitra Raghavan
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A HowdyCon update: The agenda!
If you were listening to the Group Therapy podcast Sunday, you heard Alex deliver the news about HowdyCon: We have an agenda! Here’s what he revealed…
The HowdyCon 2026 Agenda is Here!
The first wave of tickets have now officially sold out, but don’t worry, more will be released soon. In the meantime, we are excited to announce the agenda for this year’s event. The full list of talks is on view at the convention website!
You heard previously that this year’s guest speakers include Alex Barnes-Ross, Claire Headley, Phil Jones, Patty Moher, Chris Shelton. and of course, Underground Bunker author Tony Ortega. Now we can share what the weekend will entail. Here’s the brief rundown of what to expect:
FRIDAY 18th SEPTEMBER
Arrivals, registration a panel discussion and plenty of time to socialize. Two hours of bottomless pizza is included in your ticket price but you’ll have to get your own drinks.
SATURDAY 19th SEPTEMBER
Four keynote speeches and panel discussions from some of the world’s biggest SPs, a silent auction raising money for The Michael J. Rinder Aftermath Foundation and an after party packed with fun activities. A late buffet-style lunch will be provided, and is included in the cost of your ticket.
SUNDAY 20th SEPTEMBER
Breakfast and departures
HowdyCon will be taking place at multiple venues throughout New London, CT and in order to minimize potential interference from Scientology, the details will be shared exclusively with those who have purchased a ticket.
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Source Code: Actual things founder L. Ron Hubbard said on this date in history
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Scientology made a veteran psychologist feel intimidated and in fear for her physical safety in less than 8 hours. I am sure CoS considers that a win, but that's frightening.
Dr. Raghavan has nailed it to the wall. I am crying and cheering at the same time. Broke down on #21. There are no words.
Spare a thought for Cathy Fraser. After every one of these clown shows she had to report to Dave's minions, possibly even Dave himself. She was truly between a rock and a very hard place. We like to casually say, "Failure is not an option." You can say she bought into it, and she clearly has the inclination for it, but true nastiness like this comes from desperation, not malice. Remember Hannah Arendt.
Maybe a short thought. Now that they have walked away from the "arbitration" and the truth is out, she will not be doing well. They say the RPF is no longer active, but there are many levels of hell that are still in operation.