ae JOHNSON F. WALLACE POPE, JR. ee Peee ee BOKOR — POST OFFICE BOX 1368 RUPPEL & (CLEARWATER, FLORIDA 33757-1368 BURNS, LLP ‘TELEPHONE: (727) 461-1818 COUNSELORS AT LAW TAMPA = CLEARWATER = ST. PETERSBURG rusno. 192116 September 16, 2015 VIA E-MAIL: ahageli@yahoo.com Alex Hageli Re: Permanent Injunction Dear Mr. Hageli: Thank you for the courtesy of extending the time for me to respond to your email and draft pleading dated August 24, 2015. I have had a chance to review the history of this matter and would like to give you some context regarding the permanent injunction that is of concern to you In the late 1990's, Robert Minton and a group of other people, including, Mark Bunker, were involved in a number of activities targeting the Scientology religion and began picketing and demonstrating against the Church of Scientology Flag Service Organization in front of the properties of the Church in Clearwater. Their activities seriously disrupted the activities of the Church, so in November, 1999, after a physical altercation instigated by Mr. Minton, a church staff member began an injunction suit in the Pinellas County Circuit Court, which the Church joined in July, 2000. The object of the suit was not to stop protesters from protesting, but to obtain some court guidelines about how the protesters could exercise their right to protest without disrupting the operations of the Church: The activities of the Minton group were so disruptive that the Clearwater police department had to commit a substantial amount of its manpower to preserving order. The police department, although not a party to the suit, supported the issuance of an injunction to assist the department in preserving order because the demonstrations were consuming an inordinate amount of the department's resources. The lawsuit was vigorously resisted by the Minton group, but on November 4, 1999, December 2, 1999, March 1, 2000, May 24, 2000, November 30, 2000, May 17, 2001, June 27, 2001, and July 27, 2001, the court entered temporary injunctions, and after further and protracted litigation, the court entered the permanent injunction that is of concern to you. The Minton group appealed that injunction to the Second District “A 40 YEAR COMMITMENT TO OUR CLIENTS AND TO OUR COMMUNITY’=" B; ) ALEX HAGELI 0A SEPTEMBER 16, 2015 PAGE 2 Court of Appeal, and on January 3, 2003, the court affirmed the injunction in all respects, per curiam, without opinion. 837 So.2d 978 (2003). The permanent injunction has been in effect, with appellate court approval, since that date, and it was instrumental in restoring order to downtown Clearwater and at the same time protecting the right of protest, as long as the protesters operate within the guidelines of the injunction. In Florida, injunctions are governed by Rule 1.610 of the Florida Rules of Civil Procedure. The provision involved here is subsection (c) of the rule, entitled “Form and Scope.” It provides that “every injunction . . . shall be binding on the parties to the action, their officers, agents, servants, employees, and attorneys and on those persons in active concert or participation with them who receive actual notice of the injunction.” [emphasis added] You were served with a copy of the injunction because the Church has information that you have acted “in active concert or participation” with Mark Bunker, one of the defendants in the injunction case. Serving you with a copy of the injunction provides you with “actual notice” of the existence of the injunction and makes you subject to its terms. Mr. Hageli, | have been lead counsel to the Church in this injunction matter for over 15 years. The permanent injunction was entered after substantial effort and expense were undertaken by all parties involved in this issue: the Minton parties; the Church and the Clearwater Police Department. The injunction has been a major factor in restoring order to downtown Clearwater, while at the same time protecting the right of protest. For these reasons, the Clearwater Police Department has long supported the existence of this injunction and we expect it will continue to do so. It is my considered legal opinion that the Pinellas County Circuit Court will not dissolve this injunction and will find that you are governed by its terms. Of course, you remain free to file your proposed complaint if that is your desire, but | do not believe you will be successful, and ask that you consider this response carefully before taking any legal action. Very truly yours, F. Wallace Pope, Jr. cc: Client #9164244