Declaration of Robert J. Cipriano - August 5, 1999 I, Robert J. Cipriano, hereby declare and state as follows: 1. I have personal knowledge of the matters set forth herein and, if called upon to do so, I could and would competently testify thereto under oath. 2. I have primarily drafted and typed this declaration myself, free of duress, intimidation or inducement. 3. As of July 12th 1999, a certain set of circumstances and events have transpired that have caused me to write this Declaration. The events surround the introduction of Church Of Scientology private investigators, attorneys, officials and followers into my life since May 4th 1994. The circumstances and events surround "threats", "bribery", "intimidation", " "duress", "dead agenting", "fair game", "black propaganda", "slander", and "witness tampering". 4. Since May 4th 1994, my personal and professional life have been destroyed due to the acts of The Church Of Scientology and their Office Of Special Affairs, including the acts of their lawyers, Mr. Kendrick Moxon of Moxon & Kobrin, Mr. Sandy Rosen of Paul, Hastings, Janofsky & Walker and numerous officials and followers including: Kendrick Moxon, Esq.; Gary Soter, Esq.; Steven Hayes, Esq.; Timothy Bowles, Esq.; Elliot Abelson, Esq.; John Ryan; Eugene Ingram; Judy Ross; Ken Long; Isadore Chait; Rev. Glenn Barton; Michael Rinder; David Miscavige; Erla Hawkins and Joanne Weaton. I cannot be sure how many other Church of Scientology followers and officials are involved, that have not become known to me as of the date of this Declaration. I am learning on a weekly basis of additional individuals who became involved in my life, who were operatives or in some way working on behalf of Church Of Scientology and/or their Office Of Special Affairs to monitor, control, influence, harm, intimidate and tamper with me. 5. More importantly to the focus of the Declaration is my very real concern for my safety and physical protection. I have absolutely no doubt that Church of Scientology and their Office of Special Affairs will attempt further tactics of intimidation, threatening acts and, eventually attempt to have me silenced. The information contained in the Declaration provides a very clear and precise depiction, with over 1000 pages of written proof of my statements and allegations. It is my personal opinion that once this information is made public through court filings and media releases, that I will become subject to the full vengeance, of the Church of Scientology and its operatives. 6. Additionally, I have written this Declaration to bring an eventual close to what I believe to be one of the most horrendous, continuous displays of criminal acts perpetrated in the name of an IRS recognized religion in my life and possibly to bring awareness to the public about this bogus, fraudulent and extremely dangerous cult. It is my hope that all proper law enforcement officials can provide me with capable legal protection and that the media coverage will become sufficient to dissuade Church Of Scientology from harming me. Furthermore, I am not a Scientologist; however, I was brought into their private world and exposed to many of their illegal tactics. Cipriano General Background 7. I have been a businessman since 1980. At age 18 I entered into a business partnership, Capri Productions, Ltd., with Jerome L. Spiegelman. The primary focus of this business partnership was the management of entertainment performers and artists in the New York City vicinity. Over a period that spanned 1980 through February 1985, Mr. Spiegelman and I opened and managed numerous entertainment and fashion businesses. 8. In February 1985, I dissolved my partnership with Mr. Spiegelman for reasons of heavy drug use by Mr. Spiegelman and numerous legal complaints for fraud placed by his law clients. I relocated to Los Angeles, California, where I began work with Parkinson Friendly Productions under the supervision of Griffin O’Neal. I primarily created programming and production projects for Parkinson Friendly. 9. In late 1985 – early 1986, I left the entertainment business and decided to start a career in real estate. I began work with R&B Commercial Properties at Wilshire Court Financial Center and eventually was hired away from R&B by Paramount Group, Inc. at Paramount Plaza 3550/3580 Wilshire Boulevard as an Assistant Property Manager. In late 1986 – 1987, I moved to Dayton, Ohio, married Jeanette Lambert and began my first commercial real estate development, Elmwood Galleria Business Center with Paragon Realtors (Donald Nordstrom). After completing the design, financing syndication and “breaking ground”, I sold my interest in the project and relocated to New York City wherein I sought and was granted a divorce from Ms. Lambert in 1988. 10. 1988 through 1993 was spent both in New York City and Los Angeles, California, building Cipriano Development Group (CDG). I brokered real estate transactions, created real estate syndication, managed real estate properties, and in general worked particularly in the real estate business. 11. In early 1994, after losing CDG in late 1993, I became the subject of a criminal charge in May's Landing, New Jersey, for Failure Of Required Disposition over a recently acquired subsidiary of Cipriano Development Group called Artistic Builders Group. The purported crime was perpetrated by the previous owner, Mr. Peter Augay. However, because CDG had acquired the company, I was charged with the crime. The charge was falsified against me and at the time I had no funds to retain proper legal representation and therefore utilized the services of the Public Defender who eventually entered a plea bargain that required restitution and probation. During the same period, May, 1994, I was approached and threatened by a private investigator working for the Church of Scientology (COS) regarding a Mr. Graham E. Berry (see Ingram). This was a very exhausting and trying period for me. 12. In January, 1996, I elected to move from New York City back to Los Angeles, California, where I started work with the Foundation For The Declaration Of The Rights Of Children (FDRC). As their Executive Director, I created The Day Of The Child fundraising themed projects in New York City and Washington D.C. I had decided that, for personal reasons, I needed to give back to people in need and children had always been a very serious concern of mine. 13. The period from 1996 through and including July 1999 are detailed in the remaining portions of this Declaration as they go to the center of the Church of Scientology and Office of Special Affairs' circumstances and events concerning me. May 4th & 5th, 1994 Eugene Ingram (P.I. For Church Of Scientology and Moxon & Kobrin Law Firm) First Visit With Cipriano 14. On May 4th 1994, at more or less 2:00 PM, I was paid a visit by a Mr. Eugene Ingram and his female accessory at my home at 245 East 63rd Street, Apartment 1617, New York City, New York. Mr. Ingram presented himself as a Los Angeles Police Detective and presented a Detective’s Shield upon addressing me at my apartment door. Mr. Ingram had passed through a heavily guarded, high security apartment building without being noticed. Mr. Ingram stated that he had affairs that he wanted to talk to me about. I welcomed both of them into my apartment and sat and listened to him. I was under the impression that I was going to be arrested by both of them for the May’s Landing, New Jersey, criminal charge, as I had not surrendered to the New Jersey legal system. I was still seeking an attorney to answer the charges who would work with me since I had limited funds. Upon entrance into my apartment, Mr.Ingram immediately established that he was aware of my situation in New Jersey and stated that, “You should be careful and be very helpful to me!” It was a natural presumption for me to conclude that if I did not assist him in any all manners that he would arrest me and take me to New Jersey before I could retain legal representation. 15. Mr. Ingram began discussing Mr. Spiegelman, a previous business partner of mine. We discussed his law firm, our business partnership together and Mr. Spiegelman’s legal problems, which had landed him in jail after I dissolved my partnership with him. Mr. Ingram continued with questions surrounding other legal partners of Mr. Spiegelman’s including Mr. Graham E. Berry. Mr. Ingram was very interested in Mr. Berry’s legal clients and his personal habits. I asked why and what this was about. I had not seen Mr. Berry since the beginning of 1985, and had heard he had moved to Australia or New Zealand. I was aware of an open question regarding some six million dollars that was not recovered at the time Mr. Spiegelman was arrested in 1985/1986, and I began to think that Mr. Berry’s unanticipated departure to Australia or New Zealand was very mysterious. I began to relax knowing that I really had no data on Mr. Berry beyond the end of 1984, or at best, early 1985, which was prior to my departure from New York City and arrival in Los Angeles to work for Parkinson Friendly Productions. 16. Mr. Ingram continued with numerous questions regarding Mr. Berry’s personal conduct, sexual habits and his legal clients. He asked me what I knew about Mr. Berry’s gay lifestyle. I stated that I knew he lived a gay lifestyle; that he had numerous male partners who were young “boy next door” types. That in 1984, I knew and had met a David Lee who was involved with Mr. Berry. Without warning, the discussion turned domineering and combative when Mr.