DECLARATION OF DANIEL A. LEIPOLD



     I, DANIEL A. LEIPOLD, declare as follows:

     1.   I am an attorney at law duly licensed to practice

before all the courts of the State of California.

     2.   I have personal knowledge of all facts contained within

this declaration, except those stated on information and belief,

which I believe to be true.  If called to testify to any facts

contained within this declaration, I could and would be

competently able to do so.

     3.   I am a partner in the law firm of Hagenbaugh & Murphy,

attorneys of record herein for Lawrence Wollersheim.  Hagenbaugh

& Murphy also represented Lawrence Wollersheim at the trial court

level and all appellate court levels in Church of Scientology v.

Lawrence Wollersheim (1996) 42 Cal.App.4th 628.

     4.   In addition, my firm represents Mr. Wollersheim in the

United States District Court for the District of Colorado in

Bridge Publications, Inc., v. FACTNet, Inc., et al., Case Number

95-K-2143.  For the Court's convenience I have prepared a chart

entitled "Wollersheim Litigation History" which is appended to

this motion (Exhibit "H").  It sets forth in abbreviated form a

synopsis of the history of the five "Wollersheim cases."

     5.   In addition to my experience defending the "Wollersheim

cases", I have also defended the Cult Awareness Network

(hereinafter "CAN") in dozens of cases filed in state and federal

court by members of the Church of Scientology who I am informed

and believe were "fronting" these frivolous lawsuits for the

Office of Special Affairs of Scientology.  See, Hart v. Cult

Awareness Network (1993) 13 Cal.App.4th 777, 16 Cal.Rptr.2d 705. 

     6.   Through the defense of the "Wollersheim cases" and the

"CAN cases" I have become familiar with Scientology's litigation

tactics.  The Church of Scientology is no more and no less than

litigation terrorists.  It uses serial litigation to hound its

"enemies" into oblivion or as L. Ron Hubbard, founder of

Scientology has stated, to "utterly destroy" them (Exhibit "G"). 

Scientology simply goes from one specious lawsuit to the next

using "acceptable truths" (i.e., false triable issues of fact) to

sustain the suits as long as possible.  They don't care if they

lose - they don't care if they're sanctioned - they simply need

to sustain the serial litigation from their tax exempt resources

until their "enemies" "sue for peace" or collapse.

     7.   Attached hereto are the following documents:

     Exhibit "C" -  A true and correct copy of the reporter's

                    transcript of proceedings dated December 11,

                    1997, reflecting oral argument on appellant's

                    motion to vacate before the Honorable John P.

                    Shook, Judge of the Los Angeles Superior

                    Court.

     Exhibit "E" -  A true and correct copy of the reporter's

                    transcript of proceedings dated April 11,

                    1997, post-appeal proceedings in Church of

                    Scientology of California v. Wollersheim, Los

                    Angeles County Superior Court Case Number

                    BC074815, the Honorable Alan G. Buckner,

                    presiding.

     Exhibit "H" -  A true and correct copy of Scientology's

                    "secret settlement agreement" of October 1,

                    1993, with the Internal Revenue Service which

                    was downloaded from the Wall Street Journal's

                    website.

     Exhibit "I" -  A true and correct copy of the extraordinary

                    declaration of the Honorable James M. Ideman

                    dated June 17, 1993, filed in the

                    Wollersheim/Scott case (Wollersheim II, RTC

                    and CSI v. Wollersheim, 971 F.2d 364

                    consolidated with Dist.Ct. action RTC, et al.

                    v. Robin Scott, et al., Civil Action 85-

                    711MRP).

     8.   Whenever I have argued that the corporate structure of

Scientology was a "sham" it has repeatedly been Scientology's

argument that it could not conceivably be a sham as the IRS had

thoroughly investigated Scientology and granted it tax exempt

status, thus approving the reality of its corporate structure. 

Exhibit "H" is a true and correct copy of the "secret settlement

agreement" between Scientology and the IRS.  This agreement only

became public on December 30, 1997, when the Wall Street Journal

published an article.  Review of this agreement substantiates

every argument I have ever made that the corporate structure of

Scientology is a sham.  The "secret settlement agreement"

(Exhibit H), sets up a Church Tax Compliance Committee to act

ultravires of the corporate lines of 114 separate corporations to

insure compliance with the corporations' obligations to the IRS. 

Both the IRS and Scientology implicitly recognize the sham nature

of Scientology's corporate structure and the ability of RTC's

Chairman of the Board, David Miscavige to control all activity

within Scientology.  

     9.   The declaration of James M. Ideman has been attached

hereto to illustrate that this Court is by no means alone in its

holdings with reference to abusive Scientology litigation

tactics.  

     10.  I have no intention of depriving RTC or CSI of their

appellate rights herein, nor do I have any intention of depriving

them of their due process rights.  However, I request that the

Court grant this motion to expedite this appeal so that the

expense and delay of the litigation process cannot be used by

Scientology to further abuse Mr. Wollersheim and make a mockery

of the civil litigation system.  

     11.  I have attached hereto a proposed scheduling order for

consideration by the Court.  

     I declare under penalty of perjury that the foregoing is

true and correct.

     Executed this      day of February, 1998, at Orange,

California.

                                                                

                                   DANIEL A. LEIPOLD