EXHIBIT A

RAY B. JEFFREY
BOARD C ERnFIED BY TEXAS BOARD OF LEGAL SPECIALIZATION : CIVIL TRIAL LAW P ERSONAL INJURY TRIAL LAW RJEFFREY@SJMLAWYERS.COM

JEF'FREY & MITCHELL,

ATI'ORNEYS AT LAW

P.C.

2631 BULVERD E RD., SUITE 105 BULVERDE, TEXAS 78163 830.438.8935 830.438.4958 (FAX)
W WW . SJ ML AWYER S. COM

July 12, 2013

Via Email: [J2W@.'J'tiiilJJlw.n.!f.!_

Ronald P. Weil, Esq. Weil, Quaranta, McGovern P.A. 200 S. Biscayne Blvd., Suite 900 Miami, FL 33131
Via Email: Lfi!lbqbbitt(albqf!.bitt-jo.flmg_n.com

Theodore Babbitt, Esq. Babbitt, Johnson, Osborne& Le Clainche, P.A. 1641 Worthington Rd., Suite 100 West Palm Beach, FL 33409
Via Email: wallvp(ii;jpOrm.com

F. Wallace Pope, Jr., Esq. Johnson, Pope, Bokor, Ruppel & Burns, LLP 911 Chestnut Street Clearwater, FL 33756 Re: Case No. 8:13-CV-220-T27 TBM; Luis A. Garcia Saz and wife, Maria Del Rocio Burgos Garcia v. Church of Scientology Religious Trust; et al, in the United States District Court, Middle District of Florida, Tampa Division.

Dear Counsel, Please be advised that I represent Brian Culkin. The Scientology defendants have dragged him against his will into the above-referenced litigation. They have misused a declaration he signed as part of a confidential exit interview. Exit interviews and privileged documentation are routine in Scientology. Before he signed the declaration, Mr. Culkin was assured by Sarah Heller that it was for the Church' s "internal use only". Mr. Culkin was not represented by counsel in his confidential exit interview. He has no legal training or expertise. If he had been informed that his declaration might be used against the plaintiffs in this case, or in some other adversarial way, he would have refused to sign it. The . Scientology defendants violated his rights of confidentiality by

Ronald L. Weil, Esq. Theodore Babbitt, Esq. F. Wallace Pope, Jr., Esq. July 12,2013 Page 2

filing the declaration in this suit without his informed consent. As the Scientology defendants know all too well, Mr. Culkin wants no part in controversies, disputes, or proceedings with the Church. By their deceptive actions in connection with this suit, the Scientology defendants have caused Mr. Culkin considerable mental anguish. He feels betrayed by their public violation of trust and by their use of factual distortions in their pleadings. They have publicly given the appearance that Mr. Culkin supports them in their attack on the plaintiffs' legal team in this case. Nothing could be further from the truth. Mr. Culkin respects those individuals and is unaware of any wrongdoing on their part. The Scientology defendants' motion to take Mr. Culkin's deposition is designed to give the impression that he is unwilling to testify because of intimidation by the plaintiffs, their legal team, and their sympathizers. This is false. As the Scientology defendants. know, Mr. Culkin's distress and anger was with the Scientology defendants. He complained to them in the strongest possible terms about their outrageous, inexcusable behavior. The public outcry against Mr. Culkin was a direct result of the Scientology defendants' public misuse of confidential information. Mr. Culkin demanded a public apology from the Scientology defendants. Instead of making an apology, they have continued to publicly misstate and mischaracterize his position. After being thrust against his will into this suit by the Scientology defendants, he understandably rebuffed their request for him to testify on their behalf. I am writing to make clear, in response to the Scientology defendants' motion, that Mr. Culkin will appear to testify, in court or at deposition, as a reluctant, but independent witness. Any party may subpoena him or, if the Scientology defendants agree, he will appear voluntarily. Contrary to the Scientology defendants' motion, Mr. Culkin is willing to travel to Florida if his reasonable expenses are paid. We request that the parties or the Court allocate the expenses in such a way that no party may be said to be influencing his testimony. We await your response. Very truly yours,