Attorneys for Defendant
MIKE RINDER
SUPERIOR COURT OF TIE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
STEPHEN MITCHELL, LISA JAN PRECIOUS; and
KATHLEEN CAREY,
Plaintiffs,
vs.
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,
Defendants.
Case No BC 1 75367
NOTICE OF DEMURRER AND DEMURRER OF DEFENDANT
MIKE RINDER
TO VERIFIED COMPLAINT FOR LIBEL,
JOINT MEMORANDUM OF POINTS AND AUTHORITIES
IN SUPPORT OF DEMURRER AND CONCURRENTLY FILED C.C .P. SECTIONS 435 MOTION
TO STRIKE COMPLAINT
DATE: September 10,1997
TIME: 8:30 a.m.
DEPT: 62
TRIAL DATE: none assigned
DISCOVERY CUTOFF: none assigned
TO THE PLAINTIFFS, EACH OF WHOM APPEARS IN PROPRIA 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 demur to the Verified Complaint for Libel ("Complaint") filed by plaintiffs Stephen Mitchell, Lisa Jan Precious and Kathleen Carey, as follows:
DEMURRER
1. The Complaint, in its entirety, fails to state facts sufficient to constitute a cause of action. C .C.P. Section 430.10 (e).
2. This Demurrer is based upon the Complaint, its exhibits and attachments; this Notice of Demurrer and Demurrer and its accompanying Joint Memorandum of Points and Authorities in Support of Demurrer and Concurrently Filed Motion to Strike (pursuant to Local Rule 9.18(b)), 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
Respectfully submitted,
LAW OFFICES OF WILLIAM T. DRESCHER
By: (SIGNATURE: WILLIAM T. DRESCHER)
William T. Drescher
Attorneys for Defendant MIKE RINDER