Attorneys for Defendant
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OP LOS ANGELES
STEPHEN MITCHELL, LISA JAN PRECIOUS; and
DAVID MISCAVIGE , a person in the capacity
as Chairman of the Board of Religious Technology Center and Inspector General
of the Church of Scientology[TM],
MIKE RINDER, a person, in his capacity as head of the Office of Special Affairs International,
JOHN/JANE DOE #1, a person, in the capacity as head of the L. Ron Hubbard Library, and
JOHN/JANE DOE #2-99.
Case No. BC 175367
NOTICE OF MOTION AND MOTION OF DEFENDANT
TO STRIKE VERIFIED COMPLAINT FOR LIBEL
(Filed concurrently with Demurrer and Joint
Points Authorities in Support Thereof)
DATE: September 10, 1997
TIME 8:30 a.m.
TRIAL DATE: none assigned
DISCOVERY CUTOFF: none assigned
TO THE PLAINTIFFS, EACH OF WHOM APPEARS IN PRO RIA PERSONA:
PLEASE TAKE NOTICE that on September 10, 1997, at 8:30 a.m., or as soon thereafter as this matter may be heard in Department 62 of the above-captioned Court, located at 111 North Hill Street Los Angeles, California 90012-3117, defendant Mike Rinder, for himself and for no other defendant, will and hereby does move for an order striking the Verified Complaint for Libel ("Complaint") filed by plaintiffs Stephen Mitchell, Lisa Jan Precious and Kathleen Carey.
This motion is brought under the authority of California Code of Civil Procedure Sections435 and 436, and is based on the ground that the Complaint is not drawn or filed in conformity with the statutes of this state, and thus should be stricken. This Motion to Strike is filed concurrently with defendant's Demurrer to Verified Complaint for Libel, and it is supported by the Joint Memorandum of Points and Authorities submitted with that Demurrer as permitted by Local Rule 9.18 () of this Court.
This Motion to Strike is based upon the Complaint, its exhibits and attachments; this Notice of Motion and Motion; this defendant's concurrently filed Demurrer to Verified Complaint for Libel and its accompanying Joint Memorandum of Points and Authorities in Support of that Demurrer and this Motion to Strike; the Court's file in this action, and such other and further argument and evidence that may properly be presented to the Court at the hearing noticed above.
Dated August 25, 1997
LAW OFFICES OF WILLIAM T. DRESCHER
By (SIGNATURE:WILLIAM T. DRESCHER)
William T. Drescher
Attorneys for Defendant