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EXHIBIT 1
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Declaration of Laura Baxter

2. My parents were divorced and my mother, who had custody of me

during the week, enrolled me in Scientology courses for up to six hours per week

around the time I was a child.

3. At age fifteen, I became a staff member at a local Scientology

organization in Stuttgart. I had to drop out of secondary school in Germany when I

joined full time staff, so I never completed my education. As a condition of being a

staff member, I was required to undergo invasive and abusive interrogations called

“auditing” and “security checks.” And once I became a staff member, I was subject

to further interrogations and other arbitrary punishments.

4. When I was sixteen, Sea Org recruitment officers began to visit me

every night at the local Organization where I worked to manipulate, pressure, and

coerce me to sign a contract pledging to serve Scientology for life with the Sea Org. I

resisted their efforts, but the Sea Org recruiters would not take no for an answer,

continuing to show up nightly and spending an hour each time lecturing me and

cajoling me about how important and prestigious membership in Sea Org was. They

told me my hesitation was ethically problematic. Finally, they wore me down, and I

was forced to sign a contract pledging my life to Sea Org.

5. As a prerequisite to joining Sea Org, I was transported to the United

Kingdom and forced into labor on the Estates Project Force (EPF). Because I was

still a minor, my mother signed over legal guardianship of me to a Sea Org member
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and senior IASA officer. Thus, the Sea Org had ultimate legal authority over me, and

I could not travel anywhere without the permission of my Sea Org “guardian.”

6. Although I learned some English in school, my English skills were poor

when I joined Sea Org, and I had a hard time reading and understanding what

people were saying to me in English. I relied on the few other German speakers to

help interpret for me.

7. While I was working for the EPF, I had to spend eight to ten hours per

day performing arduous physical labor, and I (was not permitted adequate time to

eat proper meals or take breaks.

8. After one month of labor at EPF, I was told I would be transitioning to

work for IASA on the Freewinds. I had no choice but to do what I was told because I

was still a minor and Sea Org had complete legal authority over me.

9. As a condition of working on the Freewinds, I was once again subject

to a series of intense, manipulative, and abusive “security checks.” I was forced to

undergo dozens of these interrogations, each of which lasted for up to twelve hours,

during which I was told I could not leave the room except to eat or use the

bathroom. On the Freewinds, I was forced to work long hours on the ship with no

time off.

10. When I was seventeen, I was told that I required “more training.” I was

removed from Freewinds and sent to Scientology’s European Base in Copenhagen as

a member of IASA staff. I was forced to work as many as eighteen hours per day.
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11. In early 2004, I was transferred back to the Freewinds. When I returned

to the Freewinds, security confiscated my passport and immigration and

identification.

12. When I arrived on the ship, I was given a list of administrative tasks I

needed to complete. Some of those tasks involved signing forms, but I was not given

a chance to read the forms and no one explained what they were other than that they

were necessary for me to start working. No one ever mentioned anything about

arbitration or giving up my legal rights. They just pointed to where I should sign, and

I signed as ordered.

13. At this time, I was still not able to read English very well. That fact was

known to Sea Org officers on the ship because they had provided me with German

translations of some course materials so that I could study Scientology doctrine in

German. Even if I had been given time to read the forms I was presented with, I

would not have been able to understand them because they were in English.

14. I feared I would be punished, subject to more “security check”

interrogations, or sent back to the long hours and arduous conditions in Copenhagen

if I asked any questions about the documents, so I just did as I was told.

15. Given the date, I believe one of the documents I was ordered to sign in

March 2004 was the document attached as Exhibit B to the Declaration of Kenneth

Weber included with Defendants’ motion.

16. On the ship, I was forced to work between 11-15 hours per day as a file

administrator for IASA. Whenever I committed any real or perceived transgressions

against higher ranking officials, I was severely punished. For example, not long after

I arrived on the ship, a celebrity actor celebrated his birthday aboard the Freewinds

at David Miscavige’s invitation. Although I was directed to be present at the

gathering, a high-level IASA official falsely accused me of trying to monopolize the

actor’s attention. After this allegation, I was taken into a small room where IASA

officers screamed abusively at me. They then confined me to the extremely hot,

cramped, and dirty engine room for three days. They allowed me to leave for only

minutes at a time for meals and to return to my room for some hours of sleep. This

was the first of several times I would be sent there as punishment.

17. For the next two months, I was subject to long interrogations and

forced to confess to my alleged crimes under the direction of IASA officers. During

that time, I was not paid, I was confined to an office during the day and my room at

night, and I was kept under 24-hour surveillance. I was permitted to leave my room

only for interrogations or when I was accompanied by another Sea Org member. On

one occasion, I had no choice but to urinate into a trash can. I was forbidden from

communicating with anyone on the ship except for the specific Sea Org members

who were my handlers.

18. For four more months between about July and December 2004, I was

confined to my room and permitted to leave only to study Scientology ethics policies

for up to 14 hours per day, with breaks only for meals and to use the bathroom.

During this time, in September 2004, I was told I was being demoted from IASA and

I needed to sign something due to my “change of post.” I was not told anything else
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about the document, and I was not given a chance to read it. They simply pointed to

where I should sign, and I signed without question because I hoped it would lead to

me being released from the oppressive confinement in my room.

19. Based on the date, I now believe that the document I signed was the

one attached as Exhibit D to the Declaration of Kenneth Weber included with

Defendants’ motion.

20. In December 2004, I was finally released from confinement and

punishment and placed in a crew steward position, where I was forced to work

twelve to eighteen hours a day. After months of punishment, I was fearful that

anything I said or did might result in further restrictions or confinement. If I could be

punished that harshly for something subjective and untrue like monopolizing the

attention of an actor, punishment was possible at any time.

21. Unfortunately, my fears came to pass. I was punished on several

occasions during my time on the ship by being put to work in the engine room.

22. For all of my labor on the ship, I was supposed to be paid fifty dollars

per week, but I was rarely given full pay, at times going weeks without

compensation. This was justified on the basis that I was guilty of unnamed or

unsubstantiated transgressions, or that my shipmates had failed to generate a

required level of revenues. Because I barely retained enough money to afford basic

necessities on the ship, I was not able to save much money. I knew that if I left the

ship I would have very little money to pay for food or shelter.
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23. I began to question Scientology doctrine. I had been raised to believe

that Scientology helped people, but I saw that people were being harmed by it,

including me. I wanted to leave the ship. But I knew from experience that even

communicating the intent to leave Sea Org was a “high crime” punishable by the

most severe repercussions, and I had seen what had happened to people who tried to

leave. I feared that if I told anyone I wanted to leave that I would be severely

punished and my living and working conditions on the ship would just be made even

less tolerable.

24. Eventually, despite feeling that leaving the ship would be dangerous

and nearly impossible, I knew that I could no longer take the life on the ship of

forced hard labor and arbitrary punishment. I discussed it with Gawain, who was by

that time my husband, and we came up with a plan. Sea Org members were not

allowed to have children, and normally women who became pregnant were forced to

have abortions. But Gawain had learned that this forced abortion policy was drawing

negative attention to Scientology that the organization hoped to avoid. We decided

that if I became pregnant in advance of David Miscavige’s next visit to the

Freewinds, senior officers would want us to leave the ship rather than forcing me to

have an abortion against my will.

25. Despite being afraid of the very real possibilities that I would be forced

to have an abortion against my will or kicked off the ship and left with no money to

support me or my baby, I decided to get pregnant. As we expected, when I became

pregnant, senior officers began pressuring us to terminate the pregnancy. We refused

and were forced to undergo long interrogations and psychological punishment in the

form of “security checks” and “ethics handlings.” During these interrogations, I was

berated over and over for getting pregnant and was pressured to have an abortion. In

addition to these interrogations, we were isolated from other staff on the ship and put

under full-time surveillance by ship security.

26. After weeks of punishments and isolation, we held firm, and the officers

on the ship informed us that we would be leaving the ship. After we were told that

we would be leaving, we continued to be under full-time surveillance by ship

security, who escorted us everywhere we went. We were given directions by security

about what we had to complete before we could leave, including more interrogations

and other meetings.

27. At one point, they told us that we needed to be in a certain room at a

certain time to sign documents that were necessary before we could leave the ship.

We were directed to complete that step before we were allowed to pack our

belongings and prepare for our departure and before security would return our

passports, immigration documents, and identification and allow us to leave the ship.

28. Not only did I feel we physically had no choice to do what we were told

because of our security escort, I also feared that if we did not do exactly what we

were told in the sequence we were told to do it that our departure could be delayed

or we could be forced to stay on the ship. I also feared that they would separate us as

punishment.
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29. In the room with the two of us was a security guard and Krister

Neilsen, the officer working under the direction of Port Captain Ludwig Alpers.

Krister gave a very rough explanation of the documents in front of us. He did not

mention anything about arbitration. And even if he had used the word arbitration, I

would not have known what that meant. I was not even familiar enough with secular

laws to know that I potentially had legal claims for what had been done to me.

30. Gawain asked if we had to sign the documents, and Krister said we did.

That confirmed for me that we had no choice but to sign them to get off the ship.

31. We were given a few minutes to read the stack of documents, but it was

not enough time for me to get through the whole thing with the limited education I

had. We were not given enough time to thoroughly read the documents, and we

were not permitted to take them out of the room to review or find anyone who could

help us understand what the documents said, like an attorney.

32. I understood that if I did not sign the documents, we would be

prevented from leaving the ship and forced to undergo more hours of interrogations,

and we would not have had access to our passports and identity documents. I viewed

the time before David Miscavige’s arrival as our one window to escape the ship and

feared that even asking questions about the documents would close that window.

33. If there had been a way to leave the ship without signing the

documents, I would not have signed them.

34. I now believe that the documents I signed included the agreement in

Exhibit F to the Declaration of Kenneth Weber included with Defendants’ motion.

35. Other than the circumstances described above, I do not remember being

asked to sign any documents related to my departure, and I know I did not

voluntarily agree to any documents without being ordered to sign them.

36. Once we signed the documents, we were largely confined to our rooms,

forbidden from being in the presence of the ship’s crew, and allowed to leave our

rooms only to eat once all crew had finished eating.

37. In 2015, we moved to Australia to take care of Gawain’s elderly and

infirm paternal grandmother. Gawain’s father, a Scientologist, let us live at his

grandmother’s house and helped Gawain find a job. We began to receive constant

harassing phone calls from Scientologists asking about our status and suggesting that

we more actively participate in Scientology , develop a program to work off our

“lower conditions” and restore our status as Scientologists in good standing.

38. I feared that if we did not do something to show our commitment to

Scientology, we would face retaliation and be cut off from our Scientologist family

members, who we depended on for Gawain’s job and housing. And the phone calls

pressuring us to “come in” and take Scientology courses were nonstop. So we finally

agreed to “take” a remote Scientology course. We purchased the course materials but

never actually studied them. When we signed up for the remote course, we were

given paperwork to fill out before we could enroll. I was not given a chance to read

the paperwork, but I signed it because I felt there was no other way to get the

harassing calls to stop and to keep receiving the support of my family for work and
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housing. No one told me that it could have anything to do with my legal rights or my

experience working for the Sea Org.

39. At this time, I did not believe in Scientology, I did not want to take

Scientology courses or participate in Scientology at all, and I would not have

associated with Scientology if we had other means to get by or get the harassment to

stop.

40. I do not believe in Scientology, and I do not want to be associated with

Scientology. After all that I have been through in trying to leave Scientology, being

forced to participate in a Scientology proceeding would cause me further trauma and

contradict my current religious beliefs.

I declare under penalty of perjury that the foregoing is true and correct.

September ___, 2022 _______________________