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EXHIBIT 4
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UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

GAWAIN BAXTER et al.,

Plaintiffs,

v. Case No.: 8:22-cv-00986-TPB-JSS

DAVID MISCAVIGE et al.,

Defendants.
_____________________________/

Declaration of Michael Rinder

1. My name is Michael Rinder, I am over the age of 21, and I have

personal knowledge of the facts stated herein, which I declare are true and
correct subject to the penalty for perjury.

2. I was raised in a Scientology family from the age of six. I joined

the Sea Organization in April 1973 at the age of eighteen and remained a
full-time employee of scientology until June 2007. I am well versed on the
policies and procedures of the scientology organization.

3. The Sea Organization is scientology’s work force who sign a

billion year “Sea Org contract.” Children whose parents are Sea Org members
have signed promises to join the Sea Org for a billion years when they are as
young as six years old, and they are told to sign additional Sea Org
“contracts” when in their early to mid teens and it is time for them to be put
to work in the Sea Org. (Children in the so-called “Cadet Org” were also put
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to work, but when they arrive in Sea Org there is little to their lives other
than work.) They are not told that it is not a real, enforceable contract,
because it is useful in priming them for the many documents they will be
required to sign during their lives, none of which will be explained to them.

4. Sea Org members live in Scientology-owned facilities, and are

provided food, uniforms, medical care and transportation by the organization
in exchange for their working 16 hours a day or longer, 7 days a week, and
almost no pay, in furtherance of achieving the aims of scientology.

5. The senior echelons of scientology are manned exclusively by Sea

Org members. Every person in Religious Technology Center, Inc. (“RTC”),
Church of Scientology International, Inc. (“CSI”), Church of Scientology Flag
Service Organization, Church of Scientology Flag Ship Service Organization,
and IAS Administrations, Inc. (“IASA”) is a member of the Sea Org. You
cannot work in these organizations at any level if you are not.

6. Sea Org authority is independent of and superior to the corporate

structure of scientology. Longevity, willingness to endure extreme treatment
and conditions, proven unquestioning obedience and loyalty to higher
authorities, foremost being absolute loyalty to David Miscavige are deciding
factors in a Sea Org member’s status, reflected in their position in the
command chain leading up to David Miscavige and their “rank” (which is
based on the US Navy -- ranging from swamper at the lowest, through Petty
Officers, Midshipmen and Ensigns all the way to Captain). Sea Org members
with higher status or rank are superimposed over the scientology corporate
management structure such that even corporate officers and directors must
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report to and follow the directives of Sea Org members with higher status or
rank. The most senior Sea Org member in scientology, and thus the ultimate
authority, is Captain David Miscavige (when L. Ron Hubbard was alive, he
was the most senior Sea Org Officer, titling himself “Commodore” – that rank
was retired upon his death). As Hubbard’s successor, Sea Org “Captain” and
“leader of the scientology religion,” Miscavige has absolute control over all
persons, organizations, trusts and legal entities that are part of the
scientology network.

7. For most of the time between 1982 and 2007 I was a senior
official in CSI, the so-called mother church of scientology. I was continuously
a member of the Board of Directors of CSI from its inception in 1982 until I
escaped in 2007. During this time, I also held various positions in the
Watchdog Committee (WDC), including WDC Chairman.

8. During the majority of the time between 1982 and 2007 I was the
most senior official within CSI responsible for “external affairs,” meaning
government and media relations, investigations and intelligence operations,
as well as all litigation and legal matters. These functions are performed by
the Office of Special Affairs (“OSA”) and I was the head of OSA for most of
this time.

9. Though my title and position were within CSI, I worked under

the exclusive direction of David Miscavige (the self-titled Chairman of the
Board of RTC or “COB RTC” or nowadays simply “COB”), either personally or
through his senior representatives in RTC: Mark (“Marty”) Rathbun and to a
lesser extent Warren McShane and Mike Sutter. Even though there were
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people nominally senior to me in CSI, they were senior in title only. I

reported to Miscavige and RTC and they directed my activities.

10. Similarly, I directed the Offices of Special Affairs around the

world from the Office of Special Affairs International (“OSA Int”) in Los
Angeles, including the Office of Special Affairs located at Flag Base in
Clearwater (OSA Flag). OSA Flag is organizationally a component of FSO,
but managers of the local scientology orgs in Clearwater such as FSO and
FSSO had no authority over OSA Flag, which exclusively reports to and is
directed by the Office of Special Affairs International, the Commodore’s
Messenger Org (CMO) and RTC, in particular, David Miscavige.

11. CMO International is also organizationally a component of CSI,

but it operates under the exclusive direction of David Miscavige. There are
CMO personnel situated locally in scientology Sea Org organizations around
the world, including Clearwater. Local CMO personnel ONLY report to and
take direction from CMO International and RTC. The local RTC staff,
including in Clearwater, report to and are directed exclusively by more senior
personnel within the RTC, which is ultimately David Miscavige.

12. CMO and RTC personnel carry the weight of the authority of
David Miscavige. Every person, in every organization, no matter how senior
their position within the corporate management structure, is subordinate to
and must follow the directions of CMO and RTC personnel.

13. I have more than two decades of personal experience working for
David Miscavige dealing with the most pressing “external affairs” matters –
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from negotiations with the IRS concerning scientology’s tax-exempt status, to

silencing “attackers,” responding to media and overseeing scientology’s
litigation of numerous lawsuits. Miscavige has always maintained personal
and direct control over situations he felt threatened his position of authority
and power or would harm his image, including monitoring and handling
critics, litigation and responses to government proceedings or investigations.

14. I was hand selected by David Miscavige and brought to Los

Angeles from Florida in April 1981 to participate in the purge of the
“Guardian’s Office” which had been the arm of the former scientology
organization that had been responsible for “external affairs” but had been
caught and prosecuted by the US Government for illegal acts. This in turn
had engendered civil litigation which at the time was moving towards
judgments against the scientology and threatened to drag founder L. Ron
Hubbard into civil and potentially criminal liability. There was a corporate
restructuring, including the creation of CSI, the Guardian’s Office was
disbanded, and OSA became its heir.

15. At Miscavige’s direction, extensive and elaborate methods were

employed to shield Hubbard from liability or service of process. After
Hubbard died in 1986 and Miscavige took over, similar methods are
employed to shield Miscavige from liability, or being served with summonses
and subpoenas. This includes the security guards in all Sea Org facilities
being drilled to refuse entry to anyone seeking to serve David Miscavige and
to refuse to divulge any information about his whereabouts or to answer any
question with anything other than “I don’t know, please leave.” Since joining
the Sea Org when he was 16 years old, David Miscavige (like all other Sea
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Org members) has not maintained his own residence. He has exclusively
lived and worked in properties owned by the defendants in this case.

16. Miscavige is acutely aware of personal liability and carefully uses

subterfuge to make it appear he has no connection to unsavory or potentially
tortious or criminal activities. He talks on the phone or in person with no
record to his trusted “lieutenants” about “sensitive matters” (such as
anything relating to the “handling” of “attackers,” defined as anyone who
threatens his position or the scientology organization through exposure in the
media, on the internet or in the legal arena). If written communication about
such matters is required, it is not signed by him and gives no indication who
it was written by. At times Miscavige even writes about himself in the third
person to disguise the true authorship (e.g. “this would impact COB” rather
than “this would impact me.”) This is a practice developed by Hubbard. Other
times Miscavige instructs his lieutenants to issue orders in their name. This
happened hundreds if not thousands of times where I would relay Miscavige’s
orders to underlings in various scientology organizations around the world in
my name.

17. As part of the corporate structure designed to shield Hubbard

and now Miscavige from liability, licensing agreements were implemented
between the various corporations of scientology. These give the top of the
hierarchy (RTC and CSI) complete control over all scientology entities
(including FSO, FSSO and IAS Administrations) through legal “nuclear
options” in addition to the direct control exerted through the Sea Org chain of
command. As with all scientologists, every member of every scientology board
of directors (including FSO, FSSO and IASA Administrations) is required to
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be “in good standing” with CSI, but unlike other scientologists, “good
standing” for directors has legal significance. If CSI declares a director to no
longer be in good standing, which is an entirely discretionary decision that
CSI can make, the director must immediately be removed from the board.
CSI sublicenses scientology organizations to use the copyrights of scientology.
Those rights can also be withdrawn at any time by CSI. Similarly, RTC
licenses the use of so called “Advanced Technology” to FSO and FSSO, along
with the use of scientology’s trademarks to all scientology organizations,
including CSI. RTC can rescind these licenses should they decide to do so for
any reason. This gives RTC ultimate corporate and legal control over all
organizations, including CSI, FSO, FSSO and IASA.

18. RTC derives the entirety of its income from a license fee paid for
use of the Advanced Technology. Historically, approximately 75% of RTC’s
income has derived from the FSO, which owns and operates the numerous
properties in Clearwater known as “Flag Land Base (Flag),” and is the single
largest source of revenues in scientology. Flag is where many classes and
services are provided, as well as where most of the large programs and events
are held, and scientology members around the world travel to participate in
these services and programs and attend these events year-round.
Scientologists pay fees for each service as well as for housing and meals
provided in FSO facilities at Flag. In addition, IASA’s staff in Clearwater
seek to persuade visitors to contribute additional funds, and it regularly
sponsors its own major events to generate revenues, which are kept separate
from the funds generated by FSO. These IAS funds are distributed to
scientology orgs, including CSI, to cover expenses and fund operations
(including when OSA has a need), acquire real estate, or pay for whatever
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else Miscavige directs it to pay. For these reasons, Flag has always been the
most significant center of operations and activities for scientology, and thus
RTC has always maintained a significant presence in Clearwater, with offices
in buildings at Flag where other orgs house their primary offices and
operations.

19. The only RTC location with more staff than Clearwater was the
RTC “head office” in California where Miscavige was located. A good
proportion of the RTC staff service Miscavige directly – typists, secretaries,
household staff, cooks, assistants and the like, along with Miscavige’s
“lieutenants” in RTC. Miscavige now lives in Florida, so in addition to the
RTC staff that have traditionally been located in Clearwater to oversee the
activities of the orgs there, many of the staff that were formerly in Los
Angeles would now be located in Clearwater. RTC have traditionally had
their own offices in Clearwater, including in the Ft Harrison, Sandcastle and
West Coast buildings (and now in the so-called “Super Power” building, also
known as the “Flag Building”) and residences in a separate wing of the
Hacienda Sea Org berthing complex. These buildings are FSO facilities, RTC
rents or leases them. However, this is not a typical lessor/lessee relationship.
No FSO employees may enter any RTC spaces without authorization, though
RTC staff must be granted access to any FSO facilities if they so desire. In
the 1990s, four RTC residences were combined and renovated to create a
spacious and luxurious residence for Miscavige. Since the construction of the
residence, that is where he has always lived when in Clearwater. Miscavige’s
office is located in the Flag Building, although he can and does work in other
RTC offices around Clearwater.
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20. Until the early 2000’s there were executives in RTC who were
deputized by Miscavige to perform various functions and there were also
executives in CSI (including the highest echelon on the “Watchdog
Committee” and several other executive groups). Though they all operated
under his control and directives, there was some semblance of an organized
management structure with distributed responsibilities for oversight of
scientology’s many entities and organizations. But to consolidate his power
and control, during the first decade of the 2000’s these personnel were purged
by Miscavige, and the positions have remained unfilled. Since those purges,
the senior executive echelon of scientology only exist on paper to give the
appearance of a corporate structure. David Miscavige holds all executive
power and authority across all of scientology, with the corporations under
him performing various functions to continue maintaining the fiction of
separately managed entities operated under independent boards of directors.
However, none of the Defendants in this case have independent boards of
directors or officers; as I explain above, regardless of any appearance of
corporate separateness, CSI and RTC alone have the power to remove those
persons from their positions at any time, and there is no recourse.

21. One of the paramount concerns of David Miscavige is monitoring

“blows” (people who escape the Sea Org without permission, which is only
granted after going through an arduous and punitive “routing out” process) –
especially those who have had direct personal contact with him, or those who
have familial or other connections which lend themselves to becoming
possible legal or PR problems for him or scientology. When someone has
blown, OSA’s first responsibility is to engage in efforts to locate and “recover”
that person, through pressure and intimidation if they do not willingly
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comply. When I was the head of OSA, I had to report on any blows to
Miscavige first thing each day. In addition to the reports on the blows, he
receives a daily report on everything that has occurred in scientology
litigation around the world, the activities of “threats” and “attackers”
(including former Sea Org members who have been declared Suppressives
because they spoke out against scientology or Miscavige, reported crimes to
law enforcement or cooperated as witnesses in government investigations and
proceedings, or filed lawsuits), and all media mentions of himself or
scientology.

22. Sea Org members and scientology staff are required to sign
various documents designed to protect the organization from liability. OSA
has the job of ensuring every Sea Org member has signed these releases and
copies are kept on file. This is considered an important function of OSA.

23. Sea Org members and scientology staff are conditioned to sign
documents presented to them without questioning or even reading them. It is
understood that to question or refuse to sign will result in disciplinary action,
including any or all of the following: being confined to the premises as a
“security threat,” having a “guard” watch you 24 hours a day, being assigned
to manual labor (“MEST work” in scientology jargon), interrogation on an E-
Meter, “lower conditions” and separation from one’s spouse.

24. There is a specific procedure for anyone seeking to leave the Sea
Org, and it is particularly intensive for anyone who had access to the
activities of David Miscavige. I oversaw these protocols as the head of OSA.
Often the signing of these documents is recorded on video. These are carefully
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staged to make it appear the person has had an opportunity to change the
document, is freely signing and is even happy to do so. But the threat of not
being able to leave and being punished results in many of these people
signing whatever is presented to them (even provably untrue statements of
self-incrimination) and claiming to be happy doing so. Prior to these very
cursory sessions, exiting Sea Org members are not provided copies of the
documents they will be told to sign, they have no opportunity to consult with
an attorney. Once in the room, the exiting member is not permitted to have
anyone accompany them to help them understand the documents and they
have no meaningful opportunity to read them. Further, OSA or security staff
will be present outside the view of the camera to reinforce the very familiar
understanding that there are no choices and no freedom in the Sea Org,
including inside that room. The sense of desperation and fear of more
punishment is so great, that they will do anything expected of them just to be
able to walk out the door.

25. Until the Garcia arbitration several years ago, there had never
been a scientology “arbitration.” It remains the only one that has ever been
held. To the extent the arbitration is required to be conducted by a panel of
“arbitrators,” those arbitrators must be “in good standing” as determined by
CSI, and they are directed and controlled at all times by scientology’s
“International Justice Chief” (IJC). The IJC is a Sea Org member and
employee of CSI. The IJC, in any matters concerning dispute resolution
proceedings in the context of litigation, is directed by OSA. To maintain good
standing, arbitrators’ decisions must be approved by the IJC. Should the IJC
disagree with the findings he may order the “arbitrators” to be punished.
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