I, CRAIG J. STEIN, DECLARE:
1. I have personal knowledge of the facts stated in this declaration and if called as a witness, I could and would competently testify thereto.
2. I am an attorney at law duly admitted to practice before the Courts of New York and California and am one of the attorneys of record for defendant Larry Wollersheim.
3. Larry Wollersheim's original 2.5 million dollar judgment against Church of Scientology of California now stands with the addition of interest at $________________. Over the last several years, I have attempted to satisfy this judgment by attempting to obtain the appointment of a receiver for various assets of Church of Scientology of California. On October 26, 1994, defendant's motion for the appointment of a receiver to enforce the judgment was denied by the Honorable Diane Wayne. Defendant's motion was denied without prejudice.
4. On or about February 18, 1997, the motion was renewed by defendant before the Honorable John T. Shook and that motion too was denied.
5. Since obtaining his judgment against Church of Scientology of California, the attorneys for CSC have essentially pleaded indigency representing that it only has $35,000 in cash which was deposited with this Court. Declarant is informed and believes that Church of Scientology of California has purposely since on or about the beginning of 1981 depleted the corporate assets of Church of Scientology of California to render it a meaningless shell with no purpose other than to act as a litigation battering ram against the perceived enemies of Scientology. By stripping Church of Scientology of California of any stated purpose or daily activity, Scientology made the appointment of a receiver pointless.
I declare the foregoing to be true under the penalty of perjury pursuant to the laws of the State of California this _____ day of April, 1997 at Los Angeles, California.
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CRAIG J. STEIN, Declarant