VISALIA DIVISION MOTION TO STRIKE THE COMPLAINT AS. Complaint Filed: October 17, 2012

Transcription

1 lo Mark Goldowtz, No Paul Clfford, No Geoffrey Kng, No CALIFORNIA ANTI-SLAPP PROJECT 2903 Sacramento Street Berkeley, Calforna Phone: (510) Fax: (510) Emal: mg{at]casp.net Specal Counsel for Defendants TIM TAYLOR and ALEX GRENIER IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA BOB GRENIER, an ndvdual; GAYLE GRENIER, an ndvdual; Plantffs, vs. TIM TAYLOR, an ndvdual; ALEX GRENIER, an ndvdual; and DOES 1 TO 50; Defendants. IN AND FOR THE COUNTY OF TULARE VISALIA DIVISION Case No DECLARATION OF PAUL GRENIER IN SUPPORT OF DEFENDANTS' SPECIAL MOTION TO STRIKE THE COMPLAINT AS A MERITLESS SLAPP U' Date: Febmary 19, 2013 Tme: 8:30a.m. Department: 7 Judge: Hon. Paul A. Vortmam Complant Fled: October 17, DECLARATION OF PAUL GRENIER IN SUIPORT OF SPECIAL MOTION TO STRIKE THE PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

2 DECLARATION OF PAUL GRENIER 2 I, Paul Grener, declare, 3 1. I have personal knowledge of the facts contaned n ths declaraton, unless 4 otherwse ndcated. If called upon to testfy I am competent to do so I am thrty-one years old, born June 27, I am the eldest bologcal chld of 6 Bob Grener (Bob) and the thrd bologcal chld of Gayle Grener (Gayle). My brother s Robert 7 Grener (Robert) and my two half-brothers are Alex Grener (Alex) and Geoffrey Grener 8 (Geoffrey). 9 Sexual Molestaton lo 3. Bob dd, n fact, molest me. These are extremely humlatng and panful events to be forced to share publcly, but I am left wth no other choce at ths pont snce Bob has fled 12 ths lawsut aganst Alex and whle I would prefer not to be nvolved, I wll n no way let Alex's 3 name be tarnshed for tellng the truth. Bob began sexually molestng me at the age of fve years 14 old. These epsodes began n the small shower n the bathroom that adjoned hs and Gayle's 5 6 master bedroom. These abuses started wth me beng forced to shower wth hm naked aganst my wll. Frst, I was extremely uncomfortable and always had been by Bob walkng around 1 7 nude n front of me wth hs gentals exposed. And I knew nsde of me at fve years old that 8 there was somethng wrong wth havng to take a shower wth Bob. I knew that ths type of 19 behavor dd not occur n the homes ofmy frends even at a young age. The showers started 20 wth Bob washng me wth soap and touchng my gentals and my anus. I recall at least sx 21 occasons where Bob would nsert hs ndex fnger nsde my anus n what he would descrbe "to 22 make sure I was clean." Bob would also have me wash hs gentals wheren he would be n a 23 sexually aroused state durng these epsodes and at tmes he would not. On two occasons I was 24 forced to perform oral sex on Bob. Typcal to the combnaton ofphyscal and sexual abuse I 25 endured at Bob's hands, these showers would nvolve scaldng hot water and I remember beng 26 n pan because of the heat of the water and also scared because of what he was dong to me I brng up the combnaton ofphyscal pan beng nflcted durng the epsodes of 28 sexual abuse because ths was the tactc Bob would use when I was beng abused. In addton to DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLANT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

3 beng molested by Bob n the shower, he would also admnster "spankngs" to me. I would be 2 forced to undress and stand n front ofhm completely naked and tremblng. I often remember 3 these epsodes takng place n the room furthest away from the master bedroom. Ths was the 4 room that was occuped by Alex and Geoffrey when they stll lved at home. I menton ths 5 because there s a mulbeny tree that you can clearly see outsde the wndow of ths room and to 6 ths day I remember the tree always beng overgrown and can stll vsualze the pattern and shape 7 ofthe leaves because I would focus on the tree when he was abusng me. I do not know why I 8 dd ths but I just remember lookng out the wndow and starng at the tree and wshng I could 9 sort of fly away lke the brd I could see n the tree. Once Bob would have me undress to nudty, o he would then have me stand n front of hm and had a paddle n hs hand. He would prod my 1 1 pens and testcles wth the paddle on some occasons and then on some he would not. It was 12 then customary for me to be forced to turn around and he would stand behnd me. He would tell 3 me that I was gong to receve a certan number of spankngs. Sometmes they were fve (5) and 14 sometmes they would go as hgh as ten. These spankngs are not swaftng a chld on the butt 5 6 wth a par of underwear and pants coverng them. These are the beatngs of a grown man standng behnd a small chld and httng hm wth as much force as he possbly could. I was 17 repeatedly told by Bob to bend over and to relax. As humlatng as ths s to share, and I am 8 tremblng as I wrte ths, I remember Bob would become more angry f he could sense that my 19 buttocks were not n a relaxed state. He would tell me to spread my buttocks apart wth my 20 hands and he would take the paddle and touch my anus wth t and prod and poke me wth hs 2 1 fngers as well. After ths porton was done, Bob would then proceed to start the "spankngs." 22 All I remember once the volent beatngs started s that f you cred, moved, flnched, or dd not 23 reman n a relaxed state whle you are lterally havng someone beat you wth a wooden paddle 24 as hard as they could, you would receve more. Bob was so sadstc n the way he would do ths. 25 He would use a baseball analogy that he was "wndng up" and he would touch me gently wth 26 the paddle and then would "wnd up" agan and sometmes ths would go on for three or four 27 "wnd ups" before he would ht me as hard as he could. I never knew what to expect or when 28 they were comng and t to ths day s one ofthe most terrfyng experences ofmy lfe. I have 2 DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

4 probably thrown up three tmes whle wrtng ths porton of my declaraton. It s that upseftng 2 to me even at thrty-one years old. Once he began hs beatngs wth the paddle, I would be 3 forced to count out loud the number I was to receve and f I moved or cred, then more would be 4 admnstered. Durng ths tme, I know I was beng touched my hm napproprately between the 5 beatngs and that he would prod my anus wth hs fngers and the paddles and I could not tell f 6 he was sexually aroused or not because he was behnd me and I was n so much pan. I just 7 remember lookng at that mulbeny tree and the brds sttng on t wshng I could fly away. 8 These epsodes occurred frequently over the course ofthe next fve years untl I was 9 approxmately ten years old. After these epsodes of sexual and physcal abuse, Bob would st o down on the bed next to me and say that the holy bble commanded hm to do these thngs and 1 1 that t was my fault forcng hm to have to take such acton. He would then pray wth me and 12 have me ask god to forgve me for my actons and then I would have to thank hm for 13 "dscplnng" me and beng a responsble parent. Sckenngly, I would then have to hug hm 14 and tell hm I loved hm and that he was a good pastor Durng the tme-frame Robert s referrng to regardng hs knowledge or lack 16 thereof ofmy beng molested by Bob, I had not told anyone, ncludng Alex and Robert, that 17 Bob had done such an evl and horrfc thng to me. The only people I had confded to n prvacy 18 at that pont, were Alex's wfe Amy Joye (Amy), and a personal frend, C.D. Harbottle. These 1 9 are scars I have to lve wth my entre lfe and whle t may sound odd, t s dffcult for me to 20 speak wth any ofmy brothers regardng ths horrfc tme n my lfe. To ths day, I stll have a 2 1 dffcult tme talkng to Alex about t because of the shame and humlaton I stll feel at thrty- 22 one years old As an adult, that has stmggled wth these awful memores for the majorty of my 24 adult lfe, I can tell you that I became very good at hdng what I was feelng. I never told 25 anyone for fear of what would happen to me, my brothers, and Gayle. To ths day, one of the 26 thng that haunts me the most, s that I knew f I told Gayle, she would defend Bob and he would 27 tell her I was possessed or ths was the work of satan and I would be banshed the same way my 28 brother Geoffrey was from our home when he was approxmately ffteen or sxteen. I saw how 3 DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

5 she would run and hde when Bob would beat Alex and Geoffrey and I knew f I told her what 2 Bob was dong to me that she would not beleve me ether. I knew ths because Gayle would not 3 do anythng to stop what she saw hm dong. I could not magne what she would do f I told her 4 what Bob was dong to me and t wouldjust be my word aganst hs. I felt trapped. I never told 5 anyone untl I was an adult because Bob always got away wth everythng and nobody ever 6 stopped hm Further, I was not sure that I ever wanted anyone to know these thngs that had 8 happened to me. I had told my sster-n-law, Amy, and C.D. Harbottle, my close frend, that Bob 9 had molested me. Untl today, other than C.D. Harbottle knowng the specfcs ofthe sexual 1 0 abuse I have never went nto ths knd of detal. 8. Bob accurately states the crmnal case aganst hm for physcal chld abuse was 12 closed after Alex and I made reports to the Vsala Polce Department (VPD) n I met n 3 prvate wth Chef of Polce, Colleen Mestas, durng that tme to dscuss the dffculty I was 1 4 havng n obtanng a copy of the polce report. Chef Mestas and I dscussed the abuse at length 5 and she asked me f there were any other types of abuse such as sexual abuse that occurred. She 1 6 cautoned me to answer carefully because she s a mandatory reporter. I ntmated to Chef 1 7 Mestas that there was other abuse that was outsde the category of physcal and emotonal abuse 1 8 and that I was not ready to dsclose t at ths tme because I dd not want to be vctmzed all over 1 9 agan as I felt I had been when the crmnal complant for physcal chld abuse was fled aganst 20 Bob. I found ChefMestas to be a very concerned and compassonate offcer ofthe law and we 2 1 even spoke on the telephone later that week as she wanted to see how I was dong. In hndsght, 22 I always beleved Bob had the VPD n hs back pocket because of hs connectons to the 23 chaplan program. However, I beleve that had I fled a crmnal charge that day aganst Bob for 24 molestng me that Chef Mestas would have ensured the nvestgaton would not be 25 compromsed I met wth an attorney, Kelly Clark, along wth Alex and Amy n October of 2010, 27 n Portland, Oregon. I beleve t was late October. We consulted wth Clark to determne what 28 our rghts and legal optons were wth regard to Bob's abuse. Ths would be the frst tme I 4 DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRII(E THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

6 spoke of the sexual abuse n front of Alex. Alex heard part of t and then got up and left the 2 room because he was upset Approxmately, two months ago, I was contacted by an Ada County Sherff's 4 Investgator from Idaho and I had to recount n smlar detal to her what had transpred n our 5 home. Ths ntervew was part of an nvestgaton that resulted from Bob's efforts to have Alex 6 charged wth crmnal lbel n Idaho. As you can magne the last couple of months have been 7 dffcult as I would lke to move forward wth my lfe but am constantly havng to look back. It 8 s very panftul I gave Alex permsson to post my statement on calvarychapelabuse.com regardng lo Bob molestng me on or about Aprl 5, A true copy ofthat post s attached to Alex's frst 1 1 declaraton as Exhbt A. 12 Domestc and Chld Abuse Alex has told the truth about all ofthe abuses that occurred n our home When I was at the approxmate age of seven, after Geoffrey had been forced to 15 leave our home, Gayle was so dstraught that she and Bob were argung over Bob's not allowng 1 6 Gayle to have contact wth her bologcal chld. I remember ths was n the early mornng and 1 7 Gayle was n tears and Bob was yellng and screamng at her n ther bedroom at the back of our 1 8 home. Ths was not an uncommon occurrence. My bedroom shared an adjonng wall to thers 1 9 and I could often hear Bob beratng Gayle and forcng her through mental abuse to gve nto hs 20 demands. I brng up ths partcular nstance of abuse because to ths day t stands out n my mnd 21 as a real changng pont n Gayle's behavor movng forward from the tme I was approxmately 22 sx years old. I remember Gayle pckng up the telephone to try and reach Geoffrey who was 23 lvng n Baltmore wth hs bologcal father and stepmother. Bob became so enraged that 24 Gayle was "dsobeyng" hm that proceeded to grab her and throw her on ther bed wheren he 25 got on top ofher and put hs arms around her neck and choked her and was screamng at her that 26 a Chrstan wfe must submt to her husband. I was on the floor on my hands and knees 27 watchng Bob assault her as I peeked my head around the comer of ther open bedroom door. 28 From that moment on, I saw a complete and radcal change n Gayle's behavor. She became 5 DECLARATION OF PAUL GRENIER IN SUT'PORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

7 wthdrawn, often spendng hours on end sleepng n her bed durng the day and seemed unable to 2 cope wth what was gong on around her. I would best descrbe her behavor today as some sort 3 of copng mechansm wheren she dsassocated herself from the abuse that was occurrng n our 4 home. She became what I can only descrbe as a shell ofthe person I remember her beng when 5 I was a chld to the last tme I saw her whch was approxmately seven years ago at a grocery 6 store n Vsala, Calforna. I menton ths because I saw her and sad hello and she had a blank 7 look on her face and even after dentfyng myself as her son, Gayle stared, confused and turned 8 around and walked the other way. It was almost as f she had no dea what was occurrng. Ths 9 s very smlar to the behavor she exhbted whle I was growng up. lo 14. I was also physcally abused by Bob n addton to hm sexually abusng me. These epsodes ofphyscal abuse occurred so often that t would be mpossble for me to count 12 the number oftmes these occurred. One ofmy frst memores ofbob physcally abusng me 13 started when I was approxmately 5 years old. Bob would often have me stand n front of hm 14 whle he yelled and screamed obscentes at me. He would force me to put my hands behnd my 5 back and stand facng hm. Durng these trades Bob would taunt me that he was not gong to ht 1 6 me and would force me to step forward to hm where he would contnue tauntng that he was not gong to ht me, tellng me not to be afrad and then he would rase hs hand and ht me n the face as hard as he could. These nstances occurred many, many tmes over the course of my chldhood. Another form of hs cmel abuse that stands out to me as beng partcularly cruel and 20 humlatng s that Bob would have me go nto our backyard and pck a "swtch" as he called t. 2 1 A "swtch" was a thn branch that I would be forced to pck off of a lavender bush n our 22 backyard. After pckng ths out for Bob he would take me n the same room where he molested 23 me and have me strp naked and would proceed to whp me wth ths thn branch sometmes as 24 many as ten tmes wth hm whppng me as hard as he could. He would leave welt marks all 25 over my back, buttocks, and the back ofmy legs. I can stll hear the sound the branch made as t 26 ht my skn. Ths was one of the more excrucatngly panful nstances of physcal abuse he 27 would employ I personally wtnessed Bob physcally assault Robert on nnumerable occasons. I 6 DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

8 am twenty months older than Robert, and I have seen Bob physcally strke Robert n the face, 2 buttocks, back, and legs to the pont that Robert was so terrfed he would urnate hs pants. 3 These nstances occurred n our home on so many occasons that t would be dffcult to count 4 the number of tmes ths happened, however, from the age of fve years old and on, ths was a 5 weekly occurrence n our home Bob was especally physcally abusve toward Geoffrey. I always remember Bob 7 beng unusually volent toward hm. I actually cannot remember a day n our home where Bob 8 dd not ether ht Geoffrey or mentally and verbally abuse hm for hours on end. If I had to 9 estmate on average how many tmes per week Bob physcally abused Geoffrey I would say that 1 0 t was upwards of at least 4 tmes per week. There are 3 nstances of Bob ' s abuse of Geoffrey 1 that I would lke to address. I would lke to address these because they stand out to me as beng 12 extremely dsturbng and volent. In addton to Geoffrey beng ht n the face, whpped, 3 spanked, punched, and kcked on a weekly bass, I remember lookng outsde of my bedroom 14 wndow on a Saturday afternoon and watchng Bob ht Geoffrey n the face as he was screamng 15 and yellng. At one pont I remember Geoffrey had fallen to the ground and there was a stack of 6 frewood aganst the fence and Bob proceeded to pck up ths pece of frewood and ht Geoffrey 17 n the head, back, legs, arms, and buttocks. I stll remember Geoffreyjust lyng on the ground as 8 Bob merclessly assaulted hm. I can tell you ths nstance stands out to me because I remember 19 thnkng Bob would kll Geoffrey. The second epsode I would lke to address nvolved Bob 20 lockng Geoffrey n a coat closet that was rght outsde of our ktchen. Ths closet was no more 21 than by 3 feet wde at most and approxmately 8 feet n heght. Bob forced Geoffrey nto the 22 closet wheren there was no lght and closed the door on Geoffrey. I cannot remember the exact 23 amount oftme Geoffrey was locked n ths small closet but t was upwards of at least 4 hours. I 24 remember hearng Geoffrey cryng from the closet askng Bob to let hm out. I found out years 25 later that a congregant had heard ths story on the nternet because Alex remembers Bob lockng 26 Geoffrey n the closet and the congregant shared wth Alex that Bob and Gayle had taken them 27 nto ther home to show the congregant that there was no closet next to ther ktchen so that we 28 must be lyng. Bob and Gayle had remodeled the nsde of ther home and had dry walled over 7 DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRTKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

9 the closet and used the fact that there was no longer a closet there as a means to label Alex a lar. 2 I cannot fnd the swtches and paddle Bob would assault me wth, but t does not negate the fact 3 that Bob assaulted me. I menton ths because Bob s a master manpulator and decever and wll 4 go to any lengths to cover up what he has done. The thrd nstance that I vvdly remember 5 nvolved Bob assaultng Geoffrey near the front door of our home. Ths was actually the catalyst 6 for Geoffrey beng kcked out of our home. Bob was yellng and screamng at Geoffrey and I 7 remember Bob rasng hs fst and punchng Geoffrey wth a closed fst n the face as hard as he 8 could. Geoffrey could not have been more than 5 or 6 at the tme. I thnk t must have scared 9 Bob at how hard he punched Geoffrey because Bob mmedately banshed Geoffrey from the 10 home and told us that Geoffrey caused hm to "lose hs temper" and that he could no longer lve 1 wth us. There was and stll appears to be today, by Bob's flng ofths defamaton acton, a 12 complete and utter lack oftakng responsblty for hs actons. Bob blames everyone else for hs 3 actons whether t be that a 5 year old made hm angry, a 5 year old dd not do a task exactly as 14 he descrbed, or n present day, that Alex has re-told these nstances of abuse that Bob 15 commtted, t s always someone else's fault. Bob has never shown any mercy toward me, Alex, 1 6 and Geoffrey, n contrast, people treat ther anmals better than Bob treated us, yet once agan 17 Bob s the vctm n ths matter. The only thng Bob s a vctm ofs hs own actons. Bob s 8 angry he cannot ntmdate us nto slence any longer. Those days are long over and the scared 19 chldren Bob abused now have a voce and are grown men and are well wthn ther rght to 20 share what we endured. If Bob dd not want to be labeled a chld abuser and a chld molester; 2 1 my advce would have been not to engage n those actons toward chldren Bob would also physcally, mentally and verbally abuse Alex on what I recall as a 23 daly or sem-daly bass. I can tell you that Bob was always targetng someone n our home. It 24 may not have been the same chld everyday but there s not a day n our home I can recall where 25 one of us was not beng ht, beat, screamed at or yelled at for hours on end. Much of the 26 physcal abuse I descrbe pertanng to me, I also wtnessed Bob commttng aganst Alex. Alex 27 was frequently ht n the face by Bob wth brute force. Alex was also whpped wth these thn, 28 swtch-lke branches from our backyard. On one occason I remember Bob had Alex and 8 DECLARATION OF PAUL GRENIER N SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

10 Geoffrey stand next to each other where they were forced to take ther shrts, pants and 2 underwear off and bend over the bed n ther room. They were lterally standng rght next to 3 each other. Bob then took one ofthese swtches that was unusually long and whpped them both 4 at the same tme. Httng them anywhere he could on ther bodes. Because Bob would have us 5 count how many tmes we were beng spanked or whpped I remember ths vvdly because the 6 count had gone past 20. I also remember Alex beng n so much pan and cryng, and I do not 7 say ths to embarrass hm, but Alex had urnated durng one ofthese beatngs because I 8 remember there beng a large wet spot on the floor n hs room after ths partcular beatng. Bob 9 would not physcally abuse us wth the bedroom door shut. He would leave t wde open for the lo entre home to hear. Durng ths tme where Bob was lterally whppng Alex and Geoffrey to 1 1 the pont there were oozng and bleedng welts on ther buttocks, I can stll remember the 12 screams comng from them. I would often crawl on the floor and peek around the comer to see 13 what Bob was dong. I do not know why I would do ths but I always remember thnkng Bob 14 was gong to kll one ofus because he would be n such a rage. In hndsght, maybe I was 15 watchng to see fbob sexually abused Alex and Geoffrey n the same way he had done to me. I 1 6 remember Alex beng a partcularly nsecure adolescent n the sense that Alex had a strong 17 desre to please people and I would descrbe hm as a peace-maker. I thnk Alex beng the eldest 1 8 sblng felt lke he had to hold t together for hs younger brothers and for Gayle. Alex would 19 often ty to stop Bob from httng Geoffrey and then Alex would bear the brunt ofbob's abuse 20 for ntervenng. I always felt bad for Alex because he would try to stop Bob from assaultng 2 1 Geoffrey and then would be assaulted hmself for tryng to protect hs younger brother. Agan, 22 Bob would tell Alex and Geoffrey that these beatngs occurred because they had caused hm to 23 lose hs temper. Bob has never taken responsblty for any ofhs actons; agan t s always 24 someone else's fault that he lost hs temper. I suppose t s my fault that at 5 years old he 25 decded to sexually abuse me. Bob s the penultmate vctm n every stuaton I was never physcally or sexually abused by Gayle. However, she was aware of 27 the chld abuse that was occurrng n our home. I beleve Gayle was so terrfed of the volence 28 she saw n Bob that she felt she had nowhere to turn and dd not know what to do to help us 9 DECLARATION OF PAUL GRENIER fn SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

11 escape ths daly hell we lved n. Bob would often comment on the fact that Gayle never 2 fnshed Hgh School and dd not even have a Hgh School dploma. He would also daly remnd 3 all of us that he was the sole provder for our household and that none of us could survve 4 wthout hm. As an adult, t s so clear to me now that hs tactcs were used to slence and 5 ntmdate her as well as the rest ofus n an effort to mantan absolute and complete control over 6 the famly unt. I remember Gayle durng the tmes Alex and Geoffrey were beng abused gong 7 nto her bathroom that adjoned to the bedroom she shared wth Bob, where she would drnk 8 wne and take plls that she had hdden under the vanty snk. I can best descrbe Gayle's 9 behavor durng these epsodes of abuse as someone that would lterally lock herself n the 1 0 bathroom, self-medcate, cry and put her fngers n her ears so as not to hear what was gong and 1 1 the screams ofhep comng from her chldren. I often felt tom as to whether I should try and 12 help my brothers or go to comfort Gayle. I never knew what was the rght thng to do or who I 13 should try and help. I was so scared ofbob that I would try and avod hm as much as possble 14 durng these long and drawn out epsodes of abuse that I would try and comfort Gayle or play 5 6 board games wth Robert n our bedroom so as not to have to deal wth what was happenng rght outsde our door. I stll struggle wth feelngs of gult for not tryng to help Alex and 1 7 Geoffrey durng these tmes, but as a young chld where you are beng threatened that f you tell 1 8 the truth that you wll be put n foster care and that I would never see my famly agan, a chld at 19 that age does not have the mental capacty ofhow to process these thngs. I now can place the 20 blame squarely on Bob as he runed many lves and has caused many years of emotonal and 21 physcal pan for me, Alex, Geoffrey, Robert and Gayle I would lke to take ths opportunty to state that I beleve Gayle s projectng her 23 fears ofbob onto Alex. I beleve Robert and Gayle are as much vctms ofbob's volence as 24 Alex, Geoffrey, and me. Whle I do not beleve Robert and Gaylé's accounts ofthere beng no 25 abuse n our home are true, I beleve they both are sufferng from some nablty to come to 26 terms wth the abuse they endured at the hands of Bob. It s agan, my hope, that Gayle, wll fnd 27 the strength and determnaton to break ths cycle of volence and receve counselng and therapy 28 so that she too can lve a normal and happy lfe. I beleve all humans are enttled to that basc lo DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

12 rght and I am deeply saddened that she feels she has no opton other than to stay and cover for a 2 chld molester and chld abuser. I cannot magne the toll that must take on her daly. However, 3 t s not uncommon as we know, for the vctms and spouses of the perpetrators to cover for 4 them Whle I was not present for every vst Gayle had wth my nece, Ashley Joye 6 (Ashley), I do agree that t s Gayle that termnated her relatonshp wth Alex and Ashley. I 7 beleve she was forced to do so by Bob. I beleve ths to be true because her mother, my 8 grandmother, the late Ruth Folkert (Ruth), told me that Bob had forced her to cut tes wth Alex 9 and hs daughter and that anythng less was unacceptable. Ruth was lvng wth Bob and Gayle lo at ths tme. Ruth and I would communcate prvately as she told me on a number of occasons 1 1 that f Bob found out she was talldng to me she would be kcked out of ther home and she 12 emphatcally stated she was scared ofthe consequences ofhs fndng out about her speakng 13 wth me. Ruth also had a smlar conversaton wth my sster-n-law, Amy, wheren Ruth 14 repeated smlar statements about her fear ofbob and the consequences she would suffer f he 1 5 were to become aware of her prvate communcatons wth us I deny Gayle' s allegatons that Alex has a short temper and a hstory of volence. I 17 have never wtnessed Alex physcally harm anyone n fact I know hm to be a lovng, gentle, and 1 8 carng person. I know ths to be true because of the way he has cared for me over the course of 1 9 my lfe and because of the way I have seen hm nteract wth hs chldren and hs wfe, Amy. I 20 have never heard Alex speak of Gayle n any terms other than t "breaks hs heart" that hs 2 1 mother s trapped n an awful stuaton. 22 Abuse of CCV Staff and Members There have been many people that have attended and then left CCV over the past 24 thrty-fve years. I beleve people leaves churches for a number ofreasons. However, Bob, s 25 unusual n the Vsala church crcut as he has a reputaton for "burnng and churnng" through 26 congregants over the years. Further, when people leave hs church, he wll then go to other 27 churches and meet wth ther pastors and slander and malgn the people that have left hs church 28 and "warn" these pastors ofthe evl ways ofthe wayward congregants who have left. Bob's 11 DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

13 entre operaton s very cult-lke n hs approach. There s ether absolute loyalty to hm or you 2 are out. I have personally wtnessed hm meet wth pastors of other churches and character 3 assassnate people who have left hs church. It s for ths very reason that many frends of people 4 who left CCV found out about Bob's actons and were so dsgusted they left the church because 5 ofthese reasons. Bob has nobody but hmselfto blame for people leavng hs church and I'm 6 not sure why the last fve years would be any dfferent than people leavng n the pror thrty 7 years. Bob s vewed n a negatve lght by scores ofpeople and has been for as long as I can 8 remember. Growng up, I never heard anyone that dd not attend CCV have a knd word to say 9 about Bob. Hs poor reputaton precedes hm and has for a very long tme. lo 23. I have wtnessed Bob threaten and ntmdate hs staffnumerous tmes over the 1 1 years. I also have frsthand knowledge, along wth Amy, that Bob and Gayle, along wth Greg 12 and Suse Dowds, secretly tape recorded, prvate counselng sessons wth two couples who were 13 attendees at CCV wthout ther knowledge. Amy and I lstened to these tapes. And Bob, Gayle, 14 Greg and Suse would st and play the tapes and lsten to them n the lvng room of our home. 1 5 Ths happened on at least a dozen occasons I have shared wth Alex all ofthe accounts I menton ofbob ntmdatng and 7 abusng hs staff. 1 8 Fnancal Abuses Bob has complete and total control over the fnances ofthe church. I grew up 20 watchng Bob and Gayle use the church credt card to eat out at restaurants, travel, buy clothng, 2 1 and make whatever other purchases they deemed necessary usng church funds. Further, when 22 Bob would travel to speak at an out of town church, he would receve what he referred to as a 23 check or an "honorarum" for hs speakng servces. Whle CCV was fundng these trps whch 24 only nvolved Bob speakng on a Sunday mornng and travelng back home (nothng longer than 25 four hour drve by vehcle), Bob would check nto a hotel on a Frday evenng and stay untl 26 Monday mornng and then would return to Vsala. Addtonally, nstead ofbob usng the 27 mones he was pad for speakng at these out of town churches to remburse CCV for hs travel 28 expenses, these checks would be deposted nto hs personal checkng account. I am sure f 12 DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

14 Scacca & Company dd an audt ofbob's personal fnances over the last 30 years they would 2 fnd numerous deposts he made nto hs personal checkng account wheren he was pad for hs 3 speakng servces Bob and Gayle frequently took cash that was n an envelope handed to them by 5 ether the bookkeeper or Jm Souza, an Assstant Pastor. Bob and Gayle would use ths cash 6 they referred to as "petty cash" for whatever expendtures he wanted, frequently for personal 7 expenses. Ths cash would be used for anythng they wanted to purchase and the amount would 8 range anywhere from $500 to $1000 dependng on whatever they requested. Ths was a 9 common practce on any trp they went on, local or nternatonal. They started usng cash after or 1994, I beleve because ofssues Bob had wth the CCV board ofcredt card 1 1 transactons the board felt were not true and legtmate expenses. These ssues of fnancal abuse 12 were brought to the board's attenton by Bryan Prosser, Hank Kampen, and Guck Callahan I also shared my accounts ofbob's fnancal abuse wth Alex. 14 Bob's Involvement In Publc Affars/Controverses Bob's allegatons that he does not nterject hmself n to publc controversy are not 16 true. Bob played an actve role n beng a chaplan for the Vsala Polce Department (VPD), 17 Tulare County Sherff's Department (TCSD), organzng and hostng the Annual Vsala 8 9 Mayor's Prayer Breakfast, gvng the openng prayer at Vsala Cty Councl Meetngs, as well as playng an actve role n organzng and calculatng the runnng out of town a relgous group 20 called, "Set Free Mnstres" whch was led by Phl Agular. Bob was also actvely nvolved n 2 1 rasng money for and campagnng from the pulpt for the electon and subsequent re-electons 22 of Sherff Bll Whtman. Sherff Whtman would also speak at CCV, along wth the Chef of 23 Polce, Bruce McDermott, and hs successor, Jerry Barker. Bob has done nothng but nvolve 24 hmself n relatonshps wth local law enforcement offcals, and Sherff Bll Whtman even 25 went so far as to defend Bob n an artcle n the Fresno Bee approxmately two years ago, 26 attestng to hs moral ftness and beng of good character when the artcle at hand dealt wth the 27 ssue of Bob beng a chld abuser Bob's entre stance on moral and doctrnal ssues as they relate to the holy bble s 13 DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

15 that he s an expert. He repeatedly has held hmself out to be an expert on these topcs. 2 Frequently over the years, Bob has spoken out from the pulpt on poltcal ssues such as 3 aborton, gay rghts, gay marrage, and whch poltcans he beleves hs congregaton should 4 vote for. Hs entre publc persona s wrapped up n controversy and takng a stand for what he 5 beleves n so any statement to the contrary that he avods publc scrutny s absolutely false. 6 Further, Bob most recently gave an ntervew wth Lews Grswold ofthe Fresno Bee wheren he 7 spoke freely about why he propounded ths lawsut n the frst place. 8 Tm Taylor I frst began speakng to Tm Taylor on or about August of2009. I can't lo remember the exact date but we started communcatng after the blog on Topx.com started n 1 1 June of I was alerted to that blog by Amy, my sster-n-law who came across t on Google. 12 My recollecton ofhow Tm and I started communcatng s that he posted a generc emal 13 address fpeople wanted to get n touch wth hm and that s how I came n to contact wth hm After I establshed a level oftnst wth Tm Taylor, I shared much wth hm. We 1 5 spoke about the abuse of Alex and Geoffrey, the abuse of church members, fnancal abuse, as 16 well as the physcal and sexual abuse that I endured. I told Tm I was sexually abused by Bob 7 but dd not go nto specfc detal. 1 8 Concluson In January 2002, Bob and Gayle dd celebrate ther 25th Weddng Annversary and 20 there was a "party" at CCV. I dd stand up and say that Bob and Gayle were good parents and I 21 remember sayng a number of other pleasantres about ther marrage and them as ndvduals. 22 My reasons for dong so are two-fold: frst, I had no choce but to partcpate n these charades 23 that Bob would arrange to blatantly self-promote hmself and force our famly to gve the 24 appearance to the congregaton and the publc that we were a happy, normal, and functonng 25 famly unt; second, I dd not look at ths annversary party as any dfferent than beng forced to 26 attend mandatory publc, relgous and cvc events n Vsala and other locatons wth Bob and 27 Gayle to keep up the appearance that our famly unt was ntact and functonng normally. It was 28 a common practce for me durng these publc appearances to have a glass ofwne, take a 14 DECLARATION OF PAUL GRENIER TN SUPPORT OF SPECIAL MOTION TO STRIKE THE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor

16 Xanax, and slap on a smle to keep up the charade all the whle knowng that I was standng 2 there sayng nce thngs about the man who molested and volently physcally assaulted me Bob has nobody but hmselfto blame for hs poor reputaton. Actons have 4 consequences and the truth always has a way of comng out. Even Bob's own pastor, Chuck 5 Smth, Senor Pastor of Calvary Chapel Costa Mesa, has told me on the phone how very sorry he 6 s for what I have gone through and that he wshes Bob wouldjust stop all ofths "lawsut 7 nonsense." Pastor Dave Roph, Senor Pastor ofcalvary Chapel Also Vejo, has spoken to me 8 on a number of occasons and expressed hs deepest sympathìes and sorrow for what I am beng 9 put through because ofths lawsut that Bob has fled aganst Alex. I agree that Bob's reputaton lo 2 13 I 4 has been tarnshed, but one must ask themselves who s to blame for that? That blame falls squarely on Bob's shoulders for the crmes he has commtted aganst me and my two older halfbrothers. I declare under penalty on perjuly under the laws of the State of Calforna that the 15 foregong s true and conect. : Dated: Febma, 2013 ( 1 aul Grener DECLARATION OF PAUL GRENIER IN SUPPORT OF SPECIAL MOTION TO STRIKE TI-TE COMPLAINT PDF compresson, OCR, web optmzaton usng a watermarked evaluaton copy of CVISION PDFCompressor