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EXHIBIT 3
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Declaration of Valeska Paris

1. I am a citizen of France and Switzerland and a resident of Australia.

2. My parents were members of Scientology, and from age four, I was

subjected to Scientology “training” and indoctrination. This “training” included

subjecting me to harassment and abuse to condition me to retain my composure and

forcing me to write up false confessions of Scientology “crimes” that were later used

against me.

3. At age six, my father became a member of Sea Org, and we moved to

the Scientology base in the United Kingdom, where I was enrolled in Cadet Org and

forced to live in a dormitory with hundreds of other children separate from my

parents.

4. As a member of Cadet Org, I had very minimal schooling. I attended a

Scientology-run school where the curriculum was a Scientology check sheet used to

apply Scientology indoctrination techniques such as “word clearing.” The tasks I

was given promoted rote memorization and blind compliance, rather than critical

thinking or analysis.

5. After school each day, I was required to devote around two hours a day

to the study of Scientology. The cost of each of these Scientology courses was

recorded as a debt that I was told I would owe. In addition to studying Scientology, I

and the other Cadet Org children were forced to perform hours of unpaid work for

Scientology-affiliated entities.
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6. I was frequently punished for my alleged transgressions, and I soon

learned that reporting abuse and mistreatment I experienced from others was futile.

When I was around 11-12 years old, I was interrogated, forced to admit things I

never did, and was punished for reporting abuse or resisting mistreatment by adults.

7. I was repeatedly told as a child that I was accumulating freeloader debt,

and it was held over my head. When I was around 13, a commanding officer told

me that I would be kicked out of the dormitory and put out on the street unless I

joined Sea Org. This was a terrifying thought. I had been told stories of terrible

things that happened to people who left or were kicked out and had to fend for

themselves. I felt I had no choice but to sign a contract to join Sea Org, regardless of

whether I believed in Scientology.

8. When I was fourteen, I travelled to Flag Base, in Clearwater, Florida.

When I arrived, I was told that I first had to join the Estates Project Force (EPF). I

did not want to join the EPF, but I knew if I resisted, I would be punished with

security checks, ethics handlings, or, worse, expulsion and homelessness.

9. After I joined EPF, I did not receive any education. Instead, I was

required to clean the premises for as long as eighteen hours per day.

10. At around age fourteen, I was transferred from the Sea Org EPF to the

Commodore’s Messenger Org (CMO) EPF, where for around six months I worked

around sixteen-hour days preparing food, doing laundry, cleaning offices, and

serving as a personal assistant to Scientology executives, including Defendant David

Miscavige.
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11. During this time, I was repeatedly subjected to abusive treatment.

12. When my mother escaped from Scientology and fled to Switzerland,

even though I had nothing to do with it, I was punished for her actions. I was kicked

out of CMO, labelled a Potential Trouble Source, and placed under full time

surveillance. I was assigned lower conditions and put to work in the crew dining

room for up to twenty-one hours a day, seven days a week for the next six months.

13. When I was around 18, I was informed that David Miscavige had

ordered me to be sent to the Freewinds. At 6:30 a.m., someone came into the room

where I was sleeping, ordered me to throw my things in a bag, and placed me in the

custody of a Sea Org member, who took me against my will to the airport, boarded a

flight with me to Curacao, escorted me onto the ship, and handed the ship’s security

officer my passport. I was also required to surrender my other forms of

identification. At no time was I given a choice about living and working on the

Freewinds.

14. At around the time I was transferred to the Freewinds, I was presented

with a document to sign. At this point, I was already habituated to being given forms

that I was ordered to sign without explanation.

15. As usual with the documents I was ordered to sign during my time with

Sea Org, I was not given a chance to read the document or told anything about its

contents. Instead, the usual practice was for the person ordering me to sign the

document to quickly flip the pages, point to where to initial and sign, and I would do

so.
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16. I felt I had no choice but to sign without asking any questions. If I even

asked questions or expressed any reluctance, I knew I would be punished until I

agreed to sign it because of all the punishment I had experienced leading up to my

being send to the Freewinds.

17. When I was presented with a document, I had to sign it right away and

could not ask for more time to read it or ask questions. I do not recall any instance

during my time in Cadet Org or Sea Org in which I was given a chance to fully read

a document or ask questions about it before being ordered to sign it.

18. Based on the date of May 1996, I now believe that the document I was

ordered to sign was the agreement attached as Exhibit A to the Declaration of Sarah

Heller.

19. On the Freewinds, I told ship officials that I wanted to return to Flag

Base. As punishment, I was sent to the engine room, where I was required to climb

under the deck plates into a claustrophobic space between the pipes and clean them

with a rag. After cleaning those areas, I was covered in grease, and the only cleaning

agent I was given to remove the grease was diesel fuel. I was permitted only about

fifteen-minute meal breaks in the engine room.

20. I was punished many times during my years on the ship, including

lengthy, abusive interrogations, forced confessions, confinement and more times

being sent to the engine room. I was always fearful that anything I said might be

interpreted as rebellious and result in mental or physical punishment.

21. 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. Because I barely had enough money to afford basic necessities, I was

not able to save any money. I knew that if I left the ship I would have no money to

pay for food or shelter. I also knew that I owed significant “freeloader debt” that I

could not afford to repay. Additionally, because my travel and identification

documents had been taken from me, I knew it would be impossible to travel back to

Europe.

22. I wrote a letter to Shelly Miscavige, the wife of David Miscavige,

describing the severe mistreatment I was experiencing and telling her that I wanted

to leave the Freewinds, Sharron Weber, President of FSSO, found the letter, tore it

up and sent me to the engine room as punishment.

23. I continued to receive arbitrary, humiliating, and excessive

punishments, even when I was not at fault. For example, when CMO officers found

out I was in a romantic relationship with the Security Chief, they forced me to

prepare a handwritten confession. I was later issued a “non-enturbulation” order,

which meant that I was close to being declared a Suppressive Person that was then

posted on the ship’s notice board for the entire crew to read, humiliating me and

causing me to be subjected to shame and scorn from the crew.

24. Around February 2003, I and other Freewinds staff were sent one at a

time to sign documents, which I understood to be related to a celebrity Scientologist

who would be visiting the ship. We were not told that the documents contained an
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arbitration agreement. Again, we were not permitted to read the documents, as we

were told to hurry and sign where they indicated so the next person could sign.

25. Given the recent punishment I had been subject to and that I had

already been warned that I was close to being declared a Suppressive person, I felt I

had no choice but to sign the documents even though I was not given a chance to

read them.

26. Based on the date, I now believe that the document I was forced to sign

is the document attached as Exhibit G to the Declaration of Kenneth Weber

included with Defendants’ motion.

27. Around 2007, I was confined in the extreme heat of the engine room for

about forty-eight hours. I suffered a panic attack, went numb, and was unable to

move or call for help. When an engineer discovered me, he carried me to the control

room where I was denied medical treatment. I was berated for overreacting and sent

back to the engine room. About two weeks later, when I was again confined to the

engine room as punishment and lost consciousness due to the heat and enclosed

conditions, I did not seek medical care because I was afraid of being punished.

28. I tried again to leave the ship. Upon learning that I wanted to leave, the

senior officer in charge of discipline informed me that I was going to be declared a

Suppressive for being “uncooperative,” and she removed me from my dorm and

escorted me to a cabin monitored by a camera, where I was placed under around the

clock surveillance. I was then forced to go back to work in the hot confines of the
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engine room and be interrogated daily for the next three months. At that point, I

was so desperate to get off the ship that I contemplated suicide.

29. Unfortunately, I was sent somewhere worse. I was sent to an RPF site

in Australia to be “rehabilitated.”

30. I was prohibited from bringing most of my belongings, and they made

me pack a bag in the hallway in front of a camera to make sure I did not take more

than they permitted. While packing, I was approached by a security officer and an

FSSO official, who told me that I needed to come with them. I was also instructed

to put on makeup.

31. We went to a room where there was a video camera and a total of four

people, including Security, an Ethics Officer, and FSSO representatives. They told

me that I had to sign the documents in front of me. I was not given sufficient time to

read through the documents, nor was I permitted to take the documents to review or

have someone like an attorney help me understand them. And I was afraid that

asking questions about the documents would lead to further punishment.

32. Due to the December 2007 date on the document, I now believe that

the documents I was forced to sign was the agreement attached as Exhibit H to the

Declaration of Kenneth Weber included with Defendants’ motion.

33. Aside from under the circumstances described above, I was not asked to

sign any other documents in December 2007.

34. At the RPF, I was put to work preforming hard manual labor for many

hours a day. I slept in a crowded dorm and shared a bunk with others working
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different shifts. There was no cooling or heating. We were only permitted limited

time for brushing teeth and hygiene. The food was inadequate.

35. By this time, I no longer believed in Scientology.

36. In 2009, I married Chris Guider. I purposely became pregnant, hoping I

would finally be allowed to leave. I was denied any prenatal care and was required to

work long hours and subsist on the squash pies, cereal, stale bread and other poor-

quality food. After about six weeks of pregnancy, I had a miscarriage. I feared that

losing the baby put me at risk of being prevented from leaving Sea Org, so I did not

tell anyone other than my husband that I miscarried.

37. I was finally informed that I would be permitted to leave Sea Org, but

only once I completed security check interrogations to their satisfaction, which

became a four-month ordeal. After completing an initial round of security checks,

two senior officers were sent by David Miscavige from the United States to Australia

to put me through a second, even more harsh round of security checks and ethics

handlings. At the end of August 2009, I was finally informed that I had been granted

permission to leave Sea Org because they still thought I was pregnant.

38. But before I could leave or have my passport and identification

documents returned, I was told I had to sign more documents. I was told that, if I left

Sea Org without signing the documents, my visa would no longer be valid, and they

would report me to the immigration authorities. But if I signed the documents, they

would help me get a visa.

39. I also knew that Scientology engaged in destructive campaigns in

retaliation against people who did not leave under Scientology’s terms, or who were

perceived as potential sources of trouble.

40. Once again, I was brought into a room, not given an opportunity to

read the documents presented to me or find anyone to help me understand them, and

was instead just instructed to initial and sign where they indicated. No one told me

that the documents said anything about arbitration.

41. Had I read the documents, I would not have understood them because,

due to my lack of education and restricted life, I had no ability to understand

contracts and knew nothing about my legal rights or the law.

42. I felt that I had no choice but to sign the documents to finally be free of

Sea Org, get my passport and identification documents back, and not suffer severe

immigration consequences. I would not have signed the documents if I thought I

could leave Sea Org without doing so.

43. Based on the date of August 19, 2009, I now believe that one of the

documents I was asked to sign was the agreement attached as Exhibit I to the

Declaration of Kenneth Weber included with Defendants’ motion.

44. I did not sign the agreement in exchange for any cash payment. I

signed because I was forced to sign in order to escape Scientology

45. I have not believed in Scientology as a religion for quite some time,

which is not surprising given the abuse I suffered. Being forced to participate in a
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Scientology religious proceeding now would be traumatic and contrary to my current

religious beliefs.

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

September__,
13 2022 _____________________
Valeska Paris