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1)|Ginny Leason on behalf of Church of Scientology 2)/3875 North 44° Street Phoenix, AZ 85218 3)|602-954-1417 Defendant 1 IN THE ARCADIA BILTMORE JUSTICE COURT, ARIZONA 8 IN AND FOR THE COUNTY OF MARICOPA ‘ase No. CC2015-087583SC 9) Ora Ann Ashley, 10) Plaintiff SEPARATE STATEMENT OF FACTS IN v | SUPPORT OF MOTION FOR a SUMMARY JUDGMENT Church of Scientology, | 1 Defendant, 13) 4) 13 16, ‘The Church of Scientology hereby files this Separate Statement of Facts in Support of| 17] tpeie Motion for Summary Judgment. 18) pPARATE STATEMENT OF FACTS 15 1, Plaintiff Ora Ann Ashley sought to participate in religious services at the Church 20) of Scientology. As @ condition of participation in the Scientology religious 2 services, Ms, Ashley was required to sign a "Religious Services Enrollment 2 Application, Agreement and General Release." This Agreement is attached hereto 23] 4 Exhibit A. See Exhibit C: Declaration of Ginny Leeson, 2a4| 2. Plaintiff also signed and agreed fo an “Agreement and General Release Regarding 25) Spiritual Assistance.” This Agreement is attached hereto as Exhibit B. See 26 Exhibit C; Declaration of Ginny Leason. Both were signed on January 5, 2015, ORIGINAL Hiustice Cour ottsd RESPECTFULLY SUBMITTED this |) Church goers receive an accounting each year indicating that their donations are charitable donations to tax exempt religious institution. (On March 30, 2015, Ms. Ashley requested a repayment of $2,510 of funds donated to the Church in 2014 and 2015. Ms. Ashley refused to follow the Claims Verification Board procedures necessary to permit the ecclesiastical board to consider a return of the donations, precluding even the possibility ofa return of her donations day of June, 2015, ‘Church of Scientology 3875 North 44° Street Phoenix, AZ 85218 Defendant othe foregoing filed June J 2015, with the Clerk of Arcadia Biltmore | COPY maited June (7, 2015 to (Ora Ann Ashley 5900 East Thomas Ral #4116 EXHIBIT A CHURCH of SCIENTOLOGY or__ ARIZONA Religious Semvces Enrellnent Sippleation (print name), ‘am voluntarily signing and gbmitting to Church of Scientology of. (hereinafter “the Church”) this Religious Services Enrollment Application, Agreement and ‘General Release (hereinafter “this Agreement") so that, upon its acceptance by the Church, [may participate in Religious Services of the Scientology religion under the terms stated below. 1.1n support of my application to patiipate in the Religious Services of the Scientology religion, I represent an agree that 1) thaveseen the fl “Orientation Tunderstand { that Sctentology a religon, the Church ina church ofthe Scientology religion Scientology ‘serves te excloively ligoatinnature snd that Dianties (hich isthe study of what ‘the soul is doing to the body) ie pat of the Scientology eigion ') The term "Religious Services as used inthis Agreement mean the practices set oth the ‘wren and spoken word of1. Ron Hubbard (CLREY), the Founder ofthe Scientology religion, on Diauctics wd Scienlogy, at ministered by the ministers of the Church and allother Scientology Churches and their related organizations. These services include “auditing” which isthe Scientology religions lunigue form of religious counseling, and “training” which i the intensive study of ‘the Scientology Scripture. This Agreement is scantto incl al Religious Services of any ‘ind avalable at any Scientology Church, in the past, the present and the future ©) Tam advised thatthe Church isa separate, dlstnct legal entity and thatthe Church of Scientology International she Mother Church, is recognized by the United States Internal Revenue Service as « nonprofit tax-exempt religious organization as are allloal Churches of Scientology inthe United States 4) T acknowledge tha the Religious Services inde the ute of certain trademars and service masks which ar Hicensed tothe Church T understand that my enrolment In the Church and particpation in Religios Services doesnot ve mea lcense or any oer ight to we any ofthe tademaaand service marke and anyother Intellectual Property of the Chorch (cletvely, the “Intellectual Property”) without explicit prior writen mutboriation Shoo I decide to discontinve my involvement in the ‘Chute Tapes that any sch autorzation 1 may have received terminates upon my discontinuing my involvement, ad that ‘1 will immediately cease any use or other promotion of the Intellctal Property and ‘ell notrepresent mye ar eng athorin to.we the Inlet! Property by dvering sch eric ofanykind or sing the EMter (st defined in paragraph abe) fr ny ‘ean kaongthistobe contrary othe ans Petinng fo trademark Talo are tht | all ot in any way interfere with he we by Church of cenolgy International 0S) an the Church of ay ofthe present and fatre inlet Proper «) Netter he Church nor anyother organization thas made any sepresentation to me that my artcipation in any Scientology or Dianetics services wll have a puticula effector result fon me, I also understand thet if any sta member ofa Scientology Church or related organization makesany ims about theresa or benehis may stlain om participating ina Scientology Religious Service, that ch cals are the persona opinion ofthat staff member only and exnnot be attributed to any other Individual or organization, 2.1 recognize that Sclentology Religious Services are designed to give spiritual ald, not medical ‘weatment and that: 4) Scientology Religious Services arenotintended cor used to dlagnose or teat physica almens, orto tech or practice medicine. 1b) Iisexcasively my responsiblity fo take care of my physical and medical wel-being, and ‘under no circumstance does the Church or ny other Scientology organization have any responsibilty whatsoever in that regard. ©) T do not seek to partcipate in Scientology Religioe Services for the purpose of being cured of any physical linss, ailment or condition. 4) should not participate in any Scfentology Religie Servlce(Thavea physical mental condition that might be aggravated by the service or make he service uncomfortable ot distress to me, and f agree to assume any and all known oF unknown risks of injury, Joss, or damage resulting from my decisions An that regard. + w ©) Participation in Scientology Religious Services ‘may ental the use ofa religious insteument known asthe "E-Mete”tolocateand resolve problems and difficulties that are spiritual in ature. Tunderstand thatthe E-Meter serves, only 85a guide to Scientology ministers to assist parishioners in locating areas of petal fistress or teva, and that itis not tended. or effective for the diagnosis, treatment or prevention of any disease, or for the improvement ofheat or any bodily faction, 3.1 Intend to participate in Scientology Religious Services only for purposes of self-improvement and spiritual advancement. [agree that: 2) Achieving the benefits and goals of the Scientology religion requires my dedicated participation, because only through my own efforts can achieve those benefits and goals, by BeforeT goon toany further Religions Serve, it is essential that Tam completely satisfied ‘with my experience with he Religious Service Thad Just completed. By agreeing to proceed ‘ith further Religious Services, I will be acknowledging complete satisfction with all the Religious Services In which T had previously participated. In connection with my participation in Scientology Religious Services, the Church ‘may compile folders, including euditing, (Precear’ files, or documents containing notations and records regarding my spite progress and temporary recordings of sessions and interviews. These documents are confidential and shall be the soe property of (CStand I do hereby give up forever any and all rights of ownership, postesion, custody, contro, access, copying and viewing of ch ‘confdeni fles, documents and recordings {asdetined below), CST shall have the abote power and right to move pyseally such confidential documentsaryhere Inexchage sid conalderation for the foregoing, the ‘Church, both fr tselfand on bealf of CSI, agrees o preserve inviolate and freer the ‘confidentiality of my Precea folders and all othe eclesastical les containing any sottons regarding my spit progres, 4) wil be gulded on my spisitul pat by 2 sinister known asa Cas Supervisor who revewsrecordsf my sessions and determines Which Religious Services are approprate for may spiritual progress at tht particlar time. Talo agree that it my responsibilty to rate any questions I have about my spiral progres with my Case Supevisa T farther understand and agree that ny auditing sessions and interviews may be electronically recorded and monitored at they occur ("Recordings to factte this process In this way my Case Supervisor and “Autor can review the Recordings 8 wel at any notation made during or in connection ‘ihmy sesonsandintervinsto ensue at the quality ofthe siting Tam receiving i standard so may atin the greatest petal fain posble, lagrethathe Churchmaykecp ‘he Recordings unl they ate longer ase for my spintual growth, at which time the hch nay estoy en, They onset such recrdingand monitoring fy suing sesh andimerviews apd the relewfsuch Recordings and any notations made ding or in connection with my ssios, swell as the destruction of sich Recordings the

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