monique rathbun v. scientology: steven gregory sloat appeal

8/12/2019 Monique Rathbun v. Scientology: Steven Gregory Sloat Appeal

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Cause No. 03-14-00199-CV___________________________________________________________________________________

COURT OF APPEALSTHIRD JUDICIAL DISTRICT OF TEXAS

AUSTIN, TEXAS___________________________________________________________________________________

STEVEN GREGORY SLOAT, ED BRYAN, CHURCH OF SCIENTOLOGY

INTERNATIONAL, DAVID J. LUBOW AND MONTY DRAKE

Appellants,

v.

MONIQUE RATHBUN

Appellee.___________________________________________________________________________________

BRIEF OF APPELLANTSTEVEN GREGORY SLOAT

___________________________________________________________________________________

On Appeal from the 207th Judicial District Courtof Comal County, Texas

Trial Court No. C-2013-1082B

Hon. Dib Waldrip of the 433rd Judicial District Court, Presiding

Jonathan H. Hull

State Bar No 10253350Ashley B. Bowen

State Bar No. 24086926Reagan Burrus, PLLC

401 Main Plaza, Suite 200New Braunfels, Texas 78130

Tel. (830) 625-8026Fax (830) 625-4433

Attorneys for AppellantSteven Gregory Sloat

Oral Argument Requested

June 11, 2014

AC

03-14-00

THIRD COURT OF

AUSTIN

6/13/2014 9:3

JEFFREY

FILED IN3rd COURT OF APPEALS AUSTIN, TEXAS

6/13/2014 9:33:46 AM JEFFREY D. KYLE Clerk


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i

IDENTITY OF PARTIES AND COUNSEL

1. Appellant Steven Gregory Sloat

Represented in the trial court and on appeal by:

Jonathan H. HullAshley B. Bowen

REAGAN BURRUS PLLC401 Main Plaza, Suite 200

New Braunfels, Texas 78130Telephone: 830.625.8026

Facsimile: 830.625.4433

2. Other Appellants

a. Church of Scientology International


Ricardo G. Cedillo

Isaac J. HuronDAVIS,CEDILLO &MENDOZA,INC.

McCombs Plaza, Suite 500755 E. Mulberry Avenue

San Antonio, Texas 78212Telephone: 210.822.6666

Facsimile: 210.822.1151

George H. Spencer, Jr.CLEMENS &SPENCER

112 E. Pecan Street, Suite 1300

San Antonio, Texas 78205-1531

Telephone: 210.227.7121Facsimile: 210.227.0732

Bert H. Deixler

KENDALL BRILL KLIEGER

10100 Santa Monica Blvd., Suite 1725


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ii

Los Angeles, California 90067


Additional Counsel on appeal:

Thomas S. Leatherbury

Marc A. FullerVINSON &ELKINS LLP

Trammell Crow Center

2001 Ross Avenue, Suite 3700Dallas, Texas 75201

Telephone: 214.220.7792

Facsimile: 214.999.7792

Eric M. Lieberman

RABINOWITZ,BOUDIN,STANDARD,

KRINSKY &LIEBERMAN PC45 Broadway, Suite 1700

New York, New York 10006Telephone: 212.254.1111Facsimile: 212.674.4614

b. David Lubow


Stephanie S. Bascon

State Bar No. 19356850LAW OFFICE OF STEPHANIE S.BASCON,PLLC

297 W. San Antonio Street

New Braunfels, Texas 78130

Telephone: 830-625-2940Facsimile: [email protected]
mailto:[email protected]:[email protected]:[email protected]


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c. Monty Drake


O. Paul Dunagan

SARLES &OUIMET

370 Founders Square900 Jackson Street

Dallas, Texas 75202Telephone: 214.573.6300

Facsimile: 214.573.6306

d. Ed Bryan


Jonathan H. HullAshley B. Bowen

REAGAN BURRUS PLLC

401 Main Plaza, Suite 200

New Braunfels, Texas 78130Telephone: 830.625.8026

Facsimile: 830.625.4433

3. Appellee Monique Rathbun

Represented in the trial court and on appeal by:Ray B. Jeffrey

A. Dannette MitchellJEFFREY &MITCHELL,P.C.

2631 Bulverde Road, Suite 105

Bulverde, Texas 78163



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Marc F. Wiegand

THE WIEGAND LAW FIRM P.C.434 N. Loop 1604 West, Suite 2201

San Antonio, Texas 78232

Telephone: 210.998.3289

Elliott S. CappuccioLeslie Sara Hyman

PULMAN,CAPPUCCIO,PULLEN,BENSON,&JONES, LLP2161 N.W. Military Hwy., #400




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TABLE OF CONTENTS

IDENTITY OF PARTIES AND COUNSEL.i-iv

TABLE OF CONTENTS..v-vi

INDEX OF AUTHORITIES...vii

STATEMENT REGARDING ORAL ARGUMENT....viii

STATEMENT OF THE CASE....ix

STATEMENT OF JURISDICTION.x

STANDARD OF REVIEW..x

ISSUES PRESENTED...xi-xii

STATEMENT OF FACTS1-2

SUMMARY OF THE ARGUMENT2-4

ARGUMENT...5-10

I. THE TRIAL COURT SHOULD HAVE GRANTED SLOATS ANTI-

SLAPP MOTION TO DISMISS....5

A. The Commercial Speech Exemption Does Not Apply to MoniqueRathbuns Claims.....5

B. The Bodily Injury Exemption Does Not Apply to Headaches

and Nausea...........................5


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vi

II. THE TRIAL COURT ERRED IN HOLDING THAT MONIQUE

RATHBUNS CLAIMS WERE NOT BASED ON SLOATS FIRST

AMENDMENT RIGHTS...5

A. Monique Rathbuns Claims Relate to and Arise from Sloats Exerciseof Petition Rights.6

III. MONIQUE RATHBUNS CLAIMS MUST BE DISMISSED BECAUSE

SHE DID NOT PRESENT CLEAR AND SPECIFIC EVIDENCE TO

SUPPORT ANY CLAIM AGAINST SLOAT.......6

A. Sloat Never Disclosed any True Facts about Monique Rathbun in

Public, So Her Invasion of Privacy Claim for Public Disclosure of

Private Facts Must Be Dismissed.6

B. Monique Rathbuns Invasion of Privacy Claim for Intrusion on

Seclusion Should be Dismissed........6

C. Monique Rathbun Quit Her Job, so the Trial Court Erred When it Failed

to Dismiss Her Claim for Tortious Interference with

Contract....7

D. Monique Rathbuns Claim for Intentional Infliction of Emotional

Distress Should Be Dismissed.8

E. There is No Authority for Holding Sloat Responsible for the Acts of

Others.......8

IV. THE TRIAL COURT ERRED IN AWARDING ATTORNEYS FEES AND

COURT COSTS AGAINST THE APPELLANT AND IN FAILING TO

AWARD THE APPELLANT ITS FEES AND COSTS9

CONCLUSION AND PRAYER.9-10

CERTIFICATE OF COMPLIANCE...11

CERTIFICATE OF SERVICE...12-13

APPENDIX


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INDEX OF AUTHORITIES

Texas Appellate Cases

Kinney v. BCG Attorney Search, Inc.,

No. 03-12-00579-CV, 2014 WL 1432012,*3 (Tex. App.Austin (April 11, 2014) ................................................................... x

Statutes, Acts & Torts

Tex. Civ. Prac. & Rem. Code Chapter 27 .............................................................. viii

Tex. Civ. Prac. & Rem. Code 27.001 et seq. (the Act) ....................................... ix

Tex. Civ. Prac. & Rem. Code 27.003, 27.008 ...................................................... x

Tex. R. App. P. 9.4(i)(1) .......................................................................................... 11

Tex. R. App. P. 9.4(i)(3) .......................................................................................... 11

Tex. R. App. P. 9.7. ......................................................................................... 1-2, 5-9

Texas Citizens Participation Act....................................................................... xiii-x

Texas Anti-SLAPP statute ..................................................................................... xiii


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viii

STATEMENT REGARDING ORAL ARGUMENT

Oral argument would assist the Court. The record is voluminous, and oral

argument would give the Court an opportunity to question counsel about the

proceedings in the trial court and the evidence relating to the issues on this appeal.

This case raises important questions about the interpretation of the Sta tes anti-

SLAPP statute, the Texas Citizens Participation Act, Texas Civil Practice &

Remedies Code Chapter 27. Oral argument would give the Court an opportunity to

question counsel regarding the basis for, and the potential implications of, the trial

courts novel anderroneous interpretation of this statute.

RECORD REFERENCES

The Reporters Record will be cited as [Vol.] RR [page].

The Clerks Record will be cited as [Vol.] CR [page].

The Supplemental Clerks Record will be cited SCR [page].


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ix

STATEMENT OF THE CASE

Nature of the case This case arises out of an ongoing public controversy

between Defendant/Appellant Church of ScientologyInternational (the Church) and former Scientologist Marty

Rathbun and his wife, Plaintiff/Appellee Monique Rathbun,who became outspoken and public critics of the Church andits leadership. Monique Rathbun sued the Church, as well

as Sloat, and others in connection with this dispute.

Monique Rathbun asserted claims for invasion of privacy bypublication of private facts, intrusion upon seclusion,

tortious interference with contract, and intentional inflictionof emotional distress. 1CR28-40.

Trial court The Honorable Dib Waldrip of the 433rd Judicial DistrictCourt in Comal County presides over the trial court

proceedings.

Course of

proceedings

The trial court denied Appellants Motion to Dismiss underthe Texas Citizens Participation Act, Tex. Civ. Prac. &

Rem. Code 27.001 et seq. (the Act). 31CR3753-77. Thetrial court awarded attorneys fees and costs to Monique

Rathbun. Id.

Trial court

disposition

The trial court denied Appellants Motion to Dismiss onMarch 14, 2014. Id. Appellants timely filed their Notice of

Appeal on April 2, 2014. 44CR5056-5059.


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STATEMENT OF JURISDICTION

The Court has jurisdiction in this accelerated interlocutory appeal because

Appellants appeal the trial courts denial of their motion to dismiss under the Texas

Citizens Participation Act (the Act). Tex. Civ. Prac. & Rem. Code 27.003,

27.008.

STANDARD OF REVIEW

The Act provides for an automatic right of appeal on an expedited basis, and

for de novoreview on all issues. Kinney v. BCG Attorney Search, Inc., No. 03-12-

00579-CV, 2014 WL 1432012, *3 (Tex. App.Austin (April 11, 2014).


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ISSUES PRESENTED

1. Did the trial court err in denying Appellant Sloats Motion to Dismiss?

2. Did the trial court err in holding that the Acts exemption for legal actionsbrought against a person primarily engaged in the business of selling or leasing

goods or services arising out of commercial activity applied to Appellant?

3. Did the trial court err in holding that the Acts exemption for legal actionsseeking recovery for bodily injury applied to Monique Rathbuns complaints of

headaches and nausea?

4. Did the trial court err in holding that Monique Rathbuns claims were not

based on, relate[d] to, or in response to Sloatsexercise of his right of free

speech, right of association, or right of petition?

5. Did the trial court err in not dismissing Monique Rathbuns cause of action

for invasion of privacy by public disclosure of private facts because (a) she failed to

provide clear and specific evidence that Sloat publicly disclosed any private factsabout her; (b) Monique Rathbun cannot seek relief for the alleged disclosure of

private facts about her husband; (c) she failed to provide clear and specificevidence that Sloat disclosed private facts about her husband to more than a few

individuals, and not the public at large; (d) the alleged disclosure of facts about

Monique Rathbuns husband was a matter of legitimate public concern protected by

the First Amendment; and (e) the claim is barred by the statute of limitations?

6. Must the trial court dismiss Monique Rathbunscause of action for invasionof privacy by intrusion into seclusion when (a) she failed to provide clear and

specific evidence that Sloat intruded into private areas or matters that are within the

zone of privacy protection under Texas law; and (b) the acts of Sloat are protected

by the First Amendment?

7. Must the trial court dismiss Monique Rathbunscause of action for intentional

interference with her employment contract because (a) Sloat had no contact orinvolvement with Monique Rathbun until more than one year after she resigned from

her employment position; (b) Sloat never communicated with Monique Rathbun or

her employer; (c) Monique Rathbun failed to provide clear and specific evidencethat her employer breached or terminated her contract; and (d) the claim is barred by

the statute of limitations?


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8. Must the trial court dismiss Monique Rathbunscause of action for intentional

infliction of emotional distress when (a) she alleged it only as a gap filler andasserts claims for the same acts under other torts and intentionally avoided alleging

other torts; (b) Monique Rathbun failed to provide clear and specific evidence

Appellant committed acts that meet the standard of outrageous conduct;and (c)Appellants actionsare protected by the First Amendment?

9. Must the trial court dismiss Monique Rathbuns claims for vicarious liability

and conspiracy when those claims are derivative of her substantive claims?

10. Did the trial court err in awarding attorneys fees and costs to Monique

Rathbun, and in failing to award fees to Appellant, when it found the Motion toDismiss was not frivolous and made no finding (nor could it have) that the Motion

was solely intended to delay under the Act?


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STATEMENT OF FACTS

Sloat adopts and incorporates by reference the Statement of Facts from the

Churchs Appellants Brief. TEX.R.APP.P.9.7.

Steve Sloat

Sloat is a former Deputy U.S. Marshal. In early 2013, licensed investigator

J.R. Skaggs, hired Sloat to assist in his investigation into Rathbuns anti-Scientology

activities. 2CR302.

Sloat rented an adjacent vacant property next to Rathbuns residence/office

in Bulverde, Texas and set up a low resolution camera pointed at the Rathbuns

driveway intended to photograph the cars of visitors to the Rathbun residence/office.

2CR303-4. No camera was ever pointed at the Rathbuns house.Id.

Sloat never:

entered on to any property owned or leased by Monique Rathbun, orwent to her workplace;

peered into her home or photographed or filmed into the interior beyondthat which can be seen from a public thoroughfare;

used any form of microphone to overhear private conversations ofMonique Rathbun at her place of business or residence;

interfered with or wiretapped her telephone or Internet service; physically blocked or interfered with her freedom of movement, or

physically touched or threatened her;


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publicized any information about her; had any communications with her; or

photographed or videotaped her. 2CR303-304.

In fact, Sloat and Monique Rathbun had never seen each other in person before

she filed this suit. 2CR304.

SUMMARY OF THE ARGUMENT

Preliminarily, Sloat adopts and incorporates by reference the Summary of the

argument from the Churchs Appellants Briefas well as that of Appellant Monty

Drake, a private investigator and David Lubow (in relation to Sloatsposition as an

investigator). TEX.R.APP.P. 9.7.

Sloats actions were entirely lawful. Sloat set up surveillance cameras on an

adjacent property which took pictures of Monique Rathbunsdriveway. Sloat never

took or received a photograph depicting Monique Rathbun or the interior of her

residence/office. These limited investigative activities are protected by the First

Amendment, and the Act is intended to dismiss suits like this one at an early stage.

Additionally, Sloat is entitled to protection and standing under the Act as he was

acting on behalf of the Church in furtherance of its right to petition under the First

Amendment.


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Sloat assisted investigator Skaggs in an effort to obtain evidence of potential

significance to pending and possible litigation. Sloats participation in the petition

related activities of the Church investigator clearly related to matters of public

concern and community well-being. Monique Rathbunsclaims against Sloat are

based on, relate to and arise out of Sloatspetition related conduct.

The trial court order is fatally flawed because the court did not give separate

consideration to Sloats Motion to Dismiss. Instead, the court denied Sloats Motion

and ordered Sloat to pay Monique Rathbunsattorneys fees because of the alleged

conduct of other Defendants.

First, Rathbun generally alleges that Defendants committed certain acts

without identifying which Defendant did what. She attempts to hold Appellant Sloat

responsible for the alleged acts of all other Defendants, for the acts committed by

persons unknown and for acts allegedly committed by others more than two years

before Sloat was hired. She cannot do so without evidence supporting her vicarious

liability theories. Because she has none, Sloat can only be liable for his own acts

acts that are fully protected under the Act.

Monique Rathbun cannot assert a claim for invasion of privacy by publication

of private facts about her husband because: (1) it is restricted to invasion of her

privacy, not her husbands; (2) Sloat made no publication about Monique Rathbun

to the public; (3) any matters were of public interest; and (4) the claim is barred by


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the statute of limitations.

Monique Rathbunsprivacy claim for intrusion on seclusion fails to meet the

requirements that there be either a physical invasion of a persons property or

eavesdropping on anothers conversation with the aid of wiretaps, microphones, or

spying. It is undisputed that Sloat did none of these things.

Monique Rathbuns claim for intentional interference with her employment

contract likewise must be dismissed. Sloat never communicated with Monique

Rathbuns employer and, she voluntarily resigned.

Besides the fact that the IIED claim should be dismissed under the gap-filler

doctrine. The IIED claim also fails to meet Texass strict application of the

outrageousness element of the tort. Only the most extreme and outrageous acts will

support this claim, and the evidence showed that the actions of Sloat were never

extreme or outrageous.

Sloatsactions are protected under the First Amendment and may not be the

predicate for claims of IIED or any other tort.

Finally, the trial court violated the Act by awarding costs and fees to Monique

Rathbun. The court acknowledged Appellantsmotion was not frivolous and made

no finding that the motion was undertaken exclusively for delay. The Act requires

such a finding in order to support a fee award, so the award was improper.


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ARGUMENT

I. THE TRIAL COURT SHOULD HAVE GRANTED SLOATS ANTI-SLAPP MOTION TO DISMISS.

A. The Commercial Speech Exemption Does Not Apply to MoniqueRathbuns Claims.

Sloat adopts and incorporates by reference the Argument from the Churchs

Appellants Brief. TEX.R.APP.P. 9.7.

Monique Rathbun does not allege, and does not provide any evidence, that

Sloat was offering any goods or services, much less that he was primarily engaged

in the business of selling or leasing goods or services. Section 27.010(b). Because

it was her burden to prove that the exemption applied to the conduct of Sloat, and

she failed to do so, the trial court erred in finding this exception applied.

B. The Bodily Injury Exemption Does Not Apply to Headaches andNausea.


Appellants Brief. TEX.R.APP. P. 9.7.

II. THE TRIAL COURT ERRED IN HOLDING THAT MONIQUERATHBUNS CLAIMS WERE NOT BASED ON SLOATS FIRST

AMENDMENT RIGHTS.

Sloat adopts and incorporates by reference the Argument from theChurchs

Appellants Brief. Tex. R. App. P. 9.7.


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A. Monique Rathbuns Claims Relate to and Arise from SloatsExercise of Petition Rights.

Sloat adopts and incorporates by reference the Arguments from the opening

AppellateBriefs of the Church and Monty Drake. TEX.R.APP.P. 9.7.

III. MONIQUE RATHBUNS CLAIMS MUST BE DISMISSED BECAUSE

SHE DID NOT PRESENT CLEAR AND SPECIFICEVIDENCE TO

SUPPORT ANY CLAIM AGAINST SLOAT.



A. Sloat Never Disclosed any True Facts about Rathbun in Public, SoHer Invasion of Privacy Claim for Public Disclosure of Private

Facts Must Be Dismissed.

Sloat adopts and incorporates by reference the Arguments from the Churchs

Appellants Brief. TEX.R.APP.P. 9.7

Monique Rathbun makes no allegation that Sloat published any private facts

about her and there is no evidence that Sloat published statements about her at all,

so her claim against Sloat must be dismissed.

B. Monique Rathbuns Invasion of Privacy Claim for Intrusion onSeclusion Should Be Dismissed.



It is undisputed that Sloat did not do any of the following:

Invade or enter Monique Rathbuns place of business orresidence.


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Peer into her home, photograph or film into the interior beyond what can beseen from a public thoroughfare.

Use any form of microphone to overhear private conversations at her

business or home.

Engage, interfere with or wiretap Rathbuns telephone or Internet service. Physically block, or interfere with her freedom of movement; or Touch or threaten her or ever see her. 2CR303-304.

Sloats actions in setting up cameras on an adjacent property cameras that

were aimed not at the Rathbuns office or home, but instead on their driveway and

streets around their home do not meet any of these elements. Nor does the

communication between Sloat and Marty Rathbun.

Monique Rathbun has not shown by clear and specific evidence that the

limited actions of Sloat satisfy the elements of her claims, and because their actions

are protected by the rights of free speech and of association, these claims must be

dismissed.

C. Monique Rathbun Quit Her Job, so the Trial Court Erred When itFailed to Dismiss Her Claim for Tortious Interference with

Contract.




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Monique Rathbun quit her job over a year before Sloat was hired and first

placed his camera pointed at the Rathbuns driveway. 11CR1382; 2CR302-303.

In short, there is no evidence that Sloat did anything related to her employment

contract, and she makes no allegations against him related to her job.

D. Monique Rathbuns Claim for Intentional Infliction of EmotionalDistress Should Be Dismissed.



Sloats actsof setting up a camera to observe a driveway do not rise to the

level of extreme, outrageous or reckless conduct under Texas law. He never

entered into Monique Rathbunshouse, looked into the windows, photographed or

filmed the interior, or anything of the like. 2CR 303-304.

As such, Monique Rathbun has failed to provide clear and specific evidence

of IIED as it relates to Sloat.

E. There is No Authority for Holding Sloat Responsible for the Actsof Others.

Sloat adopts and incorporates by reference the argument from thebriefs of the

Church and Monty Drake. TEX.R.APP.P. 9.7.

Monique Rathbun asserts a boiler-plate list against each Defendant for

various theories of vicarious liability, such as conspiracy, partnership, agency, joint

enterprise, respondeat superior, concert of action, ratification, assisting or


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encouraging, and assisting and participating. 10CR1276 at 50. But she produced

no evidence, much less clear and specific evidence, to establish a prima facie case

for any of these theories against Sloat. Because of this these claims should be

dismissed.

III. THE TRIAL COURT ERRED IN AWARDING ATTORNEYS FEESAND COURT COSTS AGAINST THE APPELLANT AND IN FAILING

TO AWARD THE APPELLANT HIS FEES AND COSTS.


Appellants Brief. Tex. R. App. P. 9.7. The court declined to rule that the motions

to dismiss were frivolous or filed solely for delay but nevertheless awarded

Monique Rathbun her costs and attorneysfees. Sloat had separate and independent

counsel who filed simple joinders in the Churchs expeditious and meritorious

motion to Dismiss. The courts predicate finding of fact does not apply to Sloat.

Nor justify any award of costs against him.

CONCLUSION AND PRAYER

Appellant Sloat prays that this Court reverse the trial courts order denying

his Motion to Dismiss and awarding fees and costs against him, grant his Motion to

Dismiss, and render judgment for him, dismissing all of Monique Rathbunsclaims

with prejudice and remanding only for further proceedings concerning his claim for


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attorneys fees and costs under the Act, together with such other and further relief to

which he may be entitled.

June 11, 2014

Respectfully submitted,

/s/ Jonathan H. HullJonathan H. Hull

State Bar No 10253350

Ashley B. BowenState Bar No. 24086926

Reagan Burrus, PLLC

401 Main Plaza, Suite 200New Braunfels, Texas 78130Tel. (830) 625-8026

Fax (830) 625-4433

[email protected]@reaganburrus.com

Attorneys for Appellant

Steven Gr egory Sloat
mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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CERTIFICATE OF COMPLIANCE

Pursuant to TEX. R. APP. P. 9.4(i)(3), the undersigned hereby certifies that

this Brief of Appellant complies with the applicable word count limitation becauseit contains 1822 words, excluding the parts exempted by TEX. R. APP. P. 9.4(i)(1).

In making this certification, the undersigned has relied on the word-count functionin Microsoft Word 2010, which was used to prepare the Brief of Appellant.

/s/ Jonathan H. HullJonathan H. Hull


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CERTIFICATE OF SERVICE

The undersigned certifies that on June 11, 2014, the foregoing Brief of

Appellant was served on the following attorneys in accordance with therequirements of the Texas Rules of Appellate Procedure via electronic filing or

email.

Marc F. Wiegand

THE WIEGAND LAW FIRM,P.C.434 N. Loop 1604 West, Suite 2201

San Antonio, TX 78232

Thomas S. LeatherburyMarc A. Fuller

Daniel L. TobeyVINSON & ELKINS L.L.P.

2001 Ross Avenue, Suite 3700Dallas, Texas 75201-2975

Ricardo G. Cedillo

Isaac J. HuronLes J. Strieber III

DAVIS, CEDILLO &MENDOZA, INC.

McCombs Plaza, Suite 500755 E. Mulberry Avenue


George H. Spencer, Jr.CLEMENS & SPENCER

112 E. Pecan Street, Suite 1300

San Antonio, Texas 78205-1531

Eric M. Lieberman

RABINOWITZ,BOUDIN, STANDARD,KRINSKY & LIEBERMAN PC

45 Broadway, Suite 1700New York, NY 10006

[email protected]


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Ray B. Jeffrey

A. Dannette MitchellJEFFREY &MITCHELL,P.C.

2631 Bulverde Road, Suite 105

Bulverde, TX 78163

J. Iris GibsonHAYNES &BOONE LLP

600 Congress Ave., Suite 1300Austin, TX 78701

O. Paul DunaganSARLES &OUIMET

370 Founders Square

900 Jackson StreetDallas, TX 75202

Bert H. Deixler

KENDALL BRILL KLIEGER10100 Santa Monica Blvd., Suite 1725

Los Angeles, CA 90067

Stephanie S. Bascon

LAW OFFICE OF STEPHANIE S.BASCON,PLLC

297 W. San Antonio StreetNew Braunfels, TX 78130

Wallace B. Jefferson

Rachel Ekery

ALEXANDER DUBOSE JEFFERSON&TOWNSEND, LLP515 Congress Avenue, Suite 2350Austin, TX 78701

/s/ Jonathan H. Hull

Jonathan H. Hull


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monique rathbun v. scientology: steven gregory sloat appeal

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