OPERATION CLAMBAKE: SCIENTOLOGY COURT FILES

Part of a public library containing court papers related to lawsuits involving Scientology in some way. Collected to help lawyers and critics of Scientology in future lawsuits from or against this cult. Please report back if this has been of help, or send new contributions to the collection. Thanks. Andreas Heldal-Lund (heldal@online.no)




          CHURCH OF SCIENTOLOGY OF CALIFORNIA, Plaintiff and Appellant,
                                       v.
                 Lawrence WOLLERSHEIM, Defendant and Respondent.
                             Nos. B084686 & B086063.
            Court of Appeal, Second District, Division 3, California.
                                  Feb. 1, 1996.
                        Review Denied May 22, 1996. [FN*]

      FN* Kennard, J., dissents.

  Church attacked judgment of previous suit in which former church member was
 awarded tort damages. The Superior Court, Los Angeles County, No. BC074815,
 Edward Kakita, J., dismissed church's complaint, and church appealed.  The
 Court of Appeal, Aldrich, J., held that:  (1) church's complaint was properly
 subject to motion to strike under strategic lawsuit against public
 participation (SLAPP) law;  (2) church failed to establish probability of
 success on its claim of judicial bias;  (3) attorney fees of $130,506.71 to
 former member's counsel for trial work was reasonable;  and (4) former member
 was entitled to attorney fees for appeal.
  Affirmed.

 [1] PLEADING
 Party moving to strike suit under strategic lawsuit against public
 participation (SLAPP) law bears initial burden of establishing prima facie
 showing that plaintiff's cause of action arises from defendant's free speech or
 petition activity.  West's Ann.Cal.C.C.P. s 425.16.

 [2] PLEADING
 Defendant moving to strike suit under strategic lawsuit against public
 participation (SLAPP) law may meet its initial burden of establishing prima
 facie showing plaintiff's cause of action arises from defendant's free speech
 or petition activity by showing act which forms basis for plaintiff's cause of
 action was written or oral statement made before legislative, executive, or
 judicial proceedings.  West's Ann.Cal.C.C.P. s 425.16.

 [3] PLEADING
 If defendant moving to strike suit under strategic lawsuit against public
 participation (SLAPP) law establishes prima facie case that cause of action
 arises from defendant's free speech or petition activity, then burden shifts to
 plaintiff to establish probability that plaintiff will prevail on claim, i.e.,
 to make prima facie showing of facts which would, if proved at trial, support
 judgment in plaintiff's favor.  West's Ann.Cal.C.C.P. s 425.16.

 [4] STATUTES
 In interpreting statutes, courts first examine language of statute to determine
 legislature's intent, and if language is clear and unambiguous there is no need
 to resort to other interpretative aids, such as legislative history.

 [5] CONSTITUTIONAL LAW
 Right of access to courts is aspect of First Amendment right to petition
 government for redress of grievances.  U.S.C.A. Const.Amend. 1.

 [6] PLEADING
 Under strategic lawsuit against public participation (SLAPP) law, motion to
 strike cannot be successful unless plaintiff's action is meritless attempt to
 interfere with defendant's exercise of petition activity and is shown it lacks
 merit;  thus, SLAPP law protects defendant from retaliatory action for his or
 her exercise of legitimate petition rights but does not unconstitutionally
 interfere with plaintiffs own petition rights.  West's Ann.Cal.C.C.P. s 425.16.

 [7] PLEADING
 Cause of action arising from defendant's litigation activity may appropriately
 be subject of motion to strike under strategic lawsuit against public
 participation (SLAPP) law.  West's Ann.Cal.C.C.P. s 425.16.

 [8] PLEADING
 Church's complaint attacking prior judgment which awarded former church member
 tort damages was properly subject to motion to strike under strategic lawsuit
 against public participation (SLAPP) law, though it was not direct attack
 against former member personally, where it appeared from litigation history
 between parties that present lawsuit was brought in retaliation for earlier
 lawsuit against church, to punish former member economically for bringing that
 lawsuit, and to obliterate value of any victories over church by forcing former
 member to abandon his efforts to recover damages awarded in prior action by
 making it too costly to do so.  West's Ann.Cal.C.C.P. s 425.16.

 [9] PLEADING
 When party to lawsuit engages in course of oppressive litigation designed to
 discourage opponents' right to utilize courts to seek legal redress, trial
 court may properly apply strategic lawsuit against public participation (SLAPP)
 law.  West's Ann.Cal.C.C.P. s 425.16.

 [10] PLEADING
 In making determination under strategic lawsuit against public participation
 (SLAPP) law whether party to lawsuit engages in course of oppressive litigation
 designed to discourage opponents' right to utilize courts to seek legal
 redress, trial court may properly consider litigation history between parties.
 West's Ann.Cal.C.C.P. s 425.16.

 [11] CONSTITUTIONAL LAW
 When one party to lawsuit continuously and unsuccessfully uses litigation
 process to bludgeon opponent into submission, those actions must be
 closely scrutinized for constitutional implications.

 [12] PLEADING
 When litigant continuously and unsuccessfully uses litigation process in filing
 unmeritorious motions, appeals and lawsuits, such actions have constitutional
 implications which may be reviewed on motion to strike under strategic lawsuit
 against public participation (SLAPP) law.  West's Ann.Cal.C.C.P. s 425.16.

 [13] PLEADING
 For purposes of contesting motion to strike under strategic lawsuit against
 public participation (SLAPP) law, fact that state and federal Supreme Courts
 granted petitions for review did not prove that litigant's appellate strategy
 was successful, where neither court changed rulings below.  West's
 Ann.Cal.C.C.P. s 425.16.

 [14] PLEADING
 Even if it were assumed that motions to strike pursuant to strategic lawsuit
 against public participation (SLAPP) law were limited to issues of public
 interest, motion to strike would apply to church's action attacking judgment in
 former member's successful tort suit against church, in light of media
 coverage, extent of church's membership and assets, and fact that prior action
 concerned fundamental right under First Amendment religious practices
 guaranties.  U.S.C.A. Const.Amend. 1;  West's Ann.Cal.C.C.P. s 425.16.

 [15] PLEADING
 For purposes of motion to strike suit under strategic lawsuit against public
 participation (SLAPP) law, matters of public interest may include legislative
 and governmental activities, as well as activities that involve private person
 and entities, especially when large, powerful organization may impact lives of
 many individuals.  West's Ann.Cal.C.C.P. s 425.16.

 [16] PLEADING
 Application of strategic lawsuit against public participation (SLAPP) law to
 action arising from defendant's exercise of petition rights through litigation
 would not subject all counterclaims and other claims relating to defendant's
 prior legal action to special motion to strike, as SLAPP suit is not related to
 transaction or occurrence that is subject of complaint, but arises out of
 litigation process itself.  West's Ann.Cal.C.C.P. s 425.16.

 [17] PLEADING
 Striking of suits under strategic lawsuit against public participation (SLAPP)
 law is not limited to tort suits.  West's Ann.Cal.C.C.P. s 425.16.

 [18] PLEADING
 Church that brought action attacking prior judgment against it and in favor of
 former church member failed to establish probability of success on claim that
 judge in previous action was biased, such that action would not be struck under
 strategic lawsuit against public participation (SLAPP) law, where only support
 for its claim was inadmissible hearsay, multiple hearsay, or otherwise
 irrelevant declarations, and challenge was brought seven years after initial
 claim of bias.  West's Ann.Cal.C.C.P. ss 170 et seq., 425.16.

 [19] APPEAL AND ERROR
 On appeal from order striking suit pursuant to strategic lawsuit against public
 participation (SLAPP) law, appellate court independently reviews entire record
 to determine whether litigant made sufficient prima facie showing that it would
 prevail in light of applicable law relative to claim.  West's Ann.Cal.C.C.P. s
 425.16.

 [20] PLEADING
 Under strategic lawsuit against public participation (SLAPP) law, to establish
 probability that plaintiff will prevail on claim, plaintiff must make prima
 facie showing of facts which would, if proved at trial, support judgment in
 plaintiff's favor.  West's Ann.Cal.C.C.P. s 425.16.

 [21] PLEADING
 Requirement that court consider pleadings and affidavits of parties on motion
 to strike pursuant to strategic lawsuit against public participation (SLAPP)
 law, test is similar to standard applied to evidentiary showings in summary
 judgment motions and requires that showing be made by competent
 admissible evidence within personal knowledge of declarant;  averments on
 information and belief are insufficient.  West's Ann.Cal.C.C.P. ss 425.16,
 437c.

 [22] PLEADING
 In motion to strike pursuant to strategic lawsuit against public participation
 (SLAPP) law, pleadings frame issues to be decided.  West's Ann.Cal.C.C.P. ss
 425.16, 437c.

 [23] JUDGES
 If facts are discovered before case is submitted for decision, matter of
 judicial disqualification should be raised when facts constituting grounds for
 disqualification are first discovered and, in any event, before matter involved
 is submitted for decision;  party may not gamble on favorable decision.  West's
 Ann.Cal.C.C.P. s 170 et seq.

 [24] JUDGES
 In case where grounds for judicial disqualification are not discovered until
 after judgment is entered, statement of disqualification is timely if submitted
 at earliest practicable opportunity after disqualifying facts are discovered.
 West's Ann.Cal.C.C.P. s 170 et seq.

 [25] PLEADING
 Party cannot simply rely on allegations in its own pleadings, even if verified,
 to make evidentiary showing required in opposing motion to strike pursuant to
 strategic lawsuit against public participation (SLAPP) law.  West's
 Ann.Cal.C.C.P. s 425.16.

 [26] PLEADING
 Under strategic lawsuit against public participation (SLAPP) law, averment on
 information and belief is inadmissible at trial, and thus cannot show
 probability of prevailing on claim.  West's Ann.Cal.C.C.P. s 425.16.

 [27] PLEADING
 Assessment of probability of prevailing on claim, as determined on motion to
 strike pursuant to strategic lawsuit against public participation (SLAPP) law,
 looks to trial, and evidence that will be presented at that time.  West's
 Ann.Cal.C.C.P. s 425.16.

 [28] COSTS
 Attorney fees of $130,506.71 awarded to successful movant on motion to strike
 pursuant to strategic lawsuit against public participation (SLAPP) law were
 reasonable, where movant's counsel submitted declarations of their experience
 and expertise, information supportive of rates charged by counsel, itemized
 accounting of attorney, and expert testimony that rates requested by counsel
 were well within range of market rates charged by attorneys of equivalent
 experience, skill and expertise.  West's Ann.Cal.C.C.P. s 425.16(c).

 [29] COSTS
 Matter of reasonable attorney fees is within sound discretion of trial judge.

 [30] APPEAL AND ERROR
 Determining weight and credibility of evidence, especially credibility of
 witnesses, is special province of trier of fact.

 [31] COSTS
 In determining what constitutes reasonable compensation for attorney who has
 rendered services in connection with legal proceeding, court may and should
 consider nature of litigation, its difficulty, amount involved, skill required
 and skill employed in handling litigation, attention given, success of
 attorney's efforts, his learning, his age, and his experience in particular
 type of work demanded, intricacies and importance of litigation, labor and
 necessity for skilled legal training and ability in trying cause, and time
 consumed.

 [32] COSTS
 Successful movant on motion to strike pursuant to strategic lawsuit against
 public participation (SLAPP) law was entitled to attorney fees on appeal.
 West's Ann.Cal.C.C.P. s 425.16(c).

 [33] COSTS
 Statute authorizing attorney fee award at trial court level includes appellate
 attorney fees unless statute specifically provides otherwise.
  **624 Eric M. Lieberman, Michael Ludwig, *635 Rabinowitz, Boudin,
 Standard, Krinsky & Lieberman, New York City, Kendrick L. Moxon, Laurie J.
 Bartilson, and Moxon & Bartilson, Los Angeles, for Plaintiff and Appellant.
  Hagenbaugh & Murphy, Daniel A. Leipold, Orange and Mark Goldowitz, Oakland,
 for Defendant and Respondent.
  John C. Barker, San Francisco, Elizabeth Pritzker, Gray, Cary, Ware &
 Freidenrich and Guylyn R. Cummins, San Diego, Parker, Chapin, Flattau & Klimpl
 and Herbert L. Rosedale, New York City, as Amici Curiae.

  ALDRICH, Associate Justice.
                                  INTRODUCTION
  Plaintiff and appellant Church of Scientology (the Church) appeals from
 the order of the trial court granting the motion of defendant and respondent
 *636 Lawrence Wollersheim (Wollersheim) pursuant to Code of Civil
 Procedure section 425.16 (hereinafter, section 425.16) to dismiss the
 Church's complaint against him.  The dismissed complaint attacked the judgment
 Wollersheim had obtained against the Church in a prior action (the prior
 action). [FN1]  Section 425.16 was adopted in 1992 to deter and prevent so-
 called SLAPP (Strategic Lawsuit Against Public Participation) suits.

      FN1. Wollersheim v. Church of Scientology (1989) 212 Cal.App.3d 872,
     260 Cal.Rptr. 331.

  The Church contends the trial court erred in granting the motion because its
 action against Wollersheim is not a SLAPP suit as defined by section
 425.16.  The Church also contends the Church demonstrated the probability of
 the success of its complaint and therefore the motion should have been denied
 in any event.  Furthermore, the Church contends, the amount awarded for
 attorney fees was excessive.
  We find the motion to dismiss was properly granted and substantial evidence
 supports the award of attorney fees.  We therefore affirm the judgments.
                        FACTUAL AND PROCEDURAL BACKGROUND
   The Prior Action
  The procedural history of this litigation spans more than 15 years.
 Wollersheim filed his original action against the Church on July 28, 1980.
 Wollersheim, a former member of the Church, had alleged the Church
 intentionally and negligently inflicted severe emotional injury on him through
 certain practices, including "auditing," "disconnect," and "fair game."
  During the pendency of that lawsuit Scientology affiliates (Scientology) sued
 Wollersheim, his counsel, and his expert witnesses in the prior action in a
 RICO action in the Federal District Court in Los Angeles.  Thereafter
 Scientology petitioned the Ninth Circuit Court of Appeals to disqualify the
 entire United States District Court for the Central District of California.  In
 an unprecedented ruling the Ninth Circuit struck the motion from its records.
 Thereafter the RICO action was dismissed by the court.  Scientology once again
 appealed to the Ninth Circuit Court of Appeals which affirmed the dismissal.
 (Religious Technology Center v. Wollersheim (9th Cir.1992) 971 F.2d 364;
 cert. den. (1987) 479 U.S. 1103, 107 S.Ct. 1336, 94 L.Ed.2d 187.)
  In March 1986, Judge Ronald Swearinger, the superior court judge assigned as
 the trial judge in the prior action, ordered the Church to produce its *637
 "auditing" and "pre-clear" files on Wollersheim.  Thereafter the Church sued
 Judges Alfred Margolis (who had made previous pretrial rulings in the case) and
 Swearinger and the entire Los Angeles Superior Court in Federal District
 Court.  (Church of Scientology v. Superior Court, CV 86-1362ER.)  This suit was
 dismissed by the court in November 1986.
  After much discovery and several petitions for writs of mandate to the Court
 of Appeal brought by the Church, the prior action went to trial in superior
 court on February 18, 1986, before Judge Swearinger.  After five months of
 trial the jury returned its verdict **625 in favor of Wollersheim on July 22,
 1986.  It assessed compensatory damages in the sum of $5 million and punitive
 damages in the sum of $25 million against the Church.  On August 8, 1986, the
 Church filed its motion for new trial and for judgment notwithstanding the
 verdict both of which were denied on September 18, 1986 after three days of
 oral argument.  The Church thereafter appealed to the Second District Court of
 Appeal which reversed as to the cause of action for negligent infliction of
 emotional injury, affirmed the judgment as to the cause of action for
 intentional infliction of emotional injury and modified the judgment to reduce
 the compensatory damages to $500,000 and the punitive damages to $2 million.
 (Wollersheim v. Church of Scientology (1989) 212 Cal.App.3d 872, 260
 Cal.Rptr. 331.)  The Church then petitioned the California Supreme Court for
 review which was denied.  Upon the Church's petition for a writ of certiorari,
 the United States Supreme Court vacated the judgment of the Court of Appeal and
 remanded to that court for reconsideration in light of the Supreme Court's
 ruling in Pacific Mutual Life Insurance Co. v. Haslip (1991) 499 U.S. 1, 111
 S.Ct. 1032, 113 L.Ed.2d 1.  (Church of Scientology of California v.
 Wollersheim (1991) 499 U.S. 914, 111 S.Ct. 1298, 113 L.Ed.2d 234.)
  On remand the Court of Appeal adhered to its original decision,
 affirming the judgment subject to a remittitur.  (Wollersheim v. Church of
 Scientology (1992) 6 Cal.Rptr.2d 532.)  Once again the Church petitioned the
 California Supreme Court for review and on July 23, 1992, review was granted.
 However, on July 15, 1993, following the United States Supreme Court's decision
 in TXO Production Corp. v. Alliance Resources Corp. (1993) 509 U.S. 443, 113
 S.Ct. 2711, 125 L.Ed.2d 366, the California Supreme Court dismissed its prior
 grant of review.  The Church's subsequent petition for writ of certiorari to
 the United States Supreme Court was denied on March 7, 1994.
   The Instant Litigation
  While its appeal in the prior action was pending before the California Supreme
 Court, the Church filed this action on February 16, 1993, seeking to
 *638 set aside the judgment Wollersheim had obtained against the Church on
 July 22, 1986.  The complaint alleged that newly discovered evidence
 demonstrated that the trial judge appeared to, or did, harbor actual malice and
 prejudice against the Church at the time of the trial and may have conveyed
 prejudicial information to the jury, either directly or indirectly.
  The "newly discovered evidence" alleged in the complaint consisted of the
 following:  Post-trial interviews with jurors by the Church's attorneys
 revealed that "the jurors 'believed' that they were being followed by members
 of the [Church]."  Juror Terri Reuter stated that "the jury had been told by
 'unnamed court personnel,' whom she refused to identify, that during the trial,
 Judge Swearinger's tires had been slashed, and that his dog had been found
 dead.  She said that the jurors attributed these actions to unknown and unnamed
 members of the [Church]."  The complaint stated that Church counsel suspected
 that private investigators hired by Wollersheim's counsel "were responsible
 for 'dirty tricks' designed to implicate the Church, and prejudice the jury."
 Additionally, the complaint alleged that, because Judge Swearinger refused "to
 allow[ ] discovery into the jurors in order to establish the extent and source
 of the taint," "[t]he source of the jury's bias thus remained a mystery for
 five years."
  The complaint continued, "Finally, in an interview with William W. Horne, a
 reporter employed by The American Lawyer magazine which took place in 1992,
 Judge Swearinger revealed that he maintained a condition of mind of unfavorable
 bias against the Church during the trial of the Prior Action.  According to
 Horne, Judge Swearinger stated that his dog had drowned in the family swimming
 pool during the trial of the Prior Action, and that the judge believed that he
 had been followed when in his car throughout the trial.  The judge informed
 Horne that, while he was in possession of no evidence to corroborate the
 suspicions he harbored, he nonetheless felt that members of the Church of
 Scientology were responsible for such actions."  On March 19, 1992, Horne
 revealed Judge Swearinger's statements to the **626 Church's attorneys Eric
 M. Lieberman and Jonathan Lubell.  "For the first time, the Church and its
 attorneys suspected that the source of infection of the jury was the judge
 himself."
  The complaint continued, alleging Horne provided further details of the
 judge's statements to the Church's attorney, Michael L. Hertsberg, on March 23,
 1992.  Horne allegedly stated the judge told him the judge's veterinarian told
 him the dog was old and had died of a heart attack, yet the judge still felt
 the dog had fallen or been pushed into the pool.  Also, Horne stated the judge
 had said he felt the Church was somehow responsible for the dog's
 *639 death.  The judge also told Horne that he had been followed "a few
 times" in his car during the trial and he had assumed the Church was
 responsible for these actions.
  Horne's article in the July/August 1992 issue of The American Lawyer quoted
 Judge Swearinger as saying:
   " 'I was followed [at various times] throughout the trial ... and during
 motions for a new trial....  All kinds of things were done to intimidate me,
 and there were a number of unusual occurrences during that trial.  My car tires
 were slashed.  My collie drowned in my pool.  But there was nothing overtly
 threatening, and I didn't pay any attention to the funny stuff.' "  (Horne, The
 Two Faces of Scientology (July/Aug. 1992) Am.Law. p. 77.)
  Upon information and belief, the Church alleged that the judge described these
 incidents to court personnel during the trial and that court personnel revealed
 them to the jurors, "resulting in a jury as biased as the judge."
  The complaint referred to other occasions in which the judge made statements
 to others regarding the Church.  In April 1992, during a chamber's conference
 in an unrelated case, Judge Swearinger stated to Wollersheim's appellate
 lawyer "that he believed the award of damages ... was excessive but that he had
 deliberately chosen to allow the excessive verdict to stand because of his
 displeasure with the Church and its trial counsel."  The judge referred to the
 Church's counsel, Earl Cooley, as Earl "Fooley," "because Mr. Cooley had
 alleged that there had been tampering with the jury."  Judge Swearinger
 allegedly repeated the substance of this discourse in a telephone conversation
 with Church counsel:  he stated he did not reduce the jury's damage award
 "because such an action would have given credibility to Mr. 'Fooley's' charge
 that the jury was tainted."  These comments, the complaint alleged, revealed
 the judge possessed unfounded suspicions and unfavorable beliefs regarding the
 Church and that he "improperly permitted entry of a judgment he knew to be
 outrageous, and the result of bias and prejudice, in order to conceal that he,
 himself, was the source of the jury's bias and prejudice."  The Church alleged
 it was recently apprised of this information and prayed the judgment be
 declared null and void.  The complaint was verified by James Morrow, President
 of the Church of Scientology California.
  Wollersheim filed a special motion to strike pursuant to section 425.16,
 arguing that such a motion was authorized by that provision and that the Church
 could not demonstrate a probability that it would prevail on its
 *640 claims.  The motion, as subsequently amended, presented a number of
 contentions:  (1) the court had no jurisdiction over the action because the
 main action was pending before the California Supreme Court;  (2) the court had
 no jurisdiction because the action was "merely a disguised attempt" to bring an
 untimely motion for a new trial;  (3) the action was barred because the Church
 had not exercised due diligence in raising its claims;  (4) the Church did not
 plead and could not show that it has a meritorious defense to the main
 action;  (5) the complaint is not sufficient to set aside the judgment because
 it alleges at most intrinsic fraud;  (6) the Church could not demonstrate a
 probability that it would prevail on its claim;  (7) the Church could not
 demonstrate a probability that it could prove key facts which were alleged in
 the complaint;  (8) the action is part of the Church's litigation strategy to
 use the courts to harass opponents;  (9) the action was part of the Church's
 litigation strategy of attacking judges who rule against them as biased;  and
 (10) the Church has unclean hands and is not entitled to the **627 equitable
 relief sought.  Wollersheim argued that the Church could not meet his
 affirmative defenses:  laches, unclean hands and collateral estoppel.
  In support of his motion, Wollersheim submitted the following:  Charles
 B. O'Reilly, the lead counsel for Wollersheim at trial and on the initial
 appeal, declared that Judge Alfred Margolis ruled on the Church's pre-trial
 motions in the main action which sought to preclude any reference to the
 Church's "auditing" of Wollersheim.  When the motions were denied, two
 affiliates of the Church, Religious Technology Center (RTC) and the Church of
 Scientology International (CSI), filed "a so-called RICO action" in the United
 States District Court for the Central District of California against
 Wollersheim, his two designated experts, and his counsel, including O'Reilly,
 "seeking basically the same relief that had been denied by Judge Margolis."  A
 Special Master determined the action to be "not only frivolous but bordering on
 malicious," and accordingly the action was dismissed by the judge of the
 District Court, the dismissal affirmed on appeal in (Religious Technology
 Center v. Wollersheim (9th Cir.1992) 971 F.2d 364.)  While the RICO action was
 still pending, the Church, RTC, and/or CSI filed a motion/petition in the Ninth
 Circuit seeking to disqualify the entire U.S. District Court for the Central
 District of California on the ground of bias and prejudice against the Church.
 The motion/petition was ordered struck from the record by the Ninth Circuit.
  O'Reilly declared that, due to his calendar, Judge Margolis withdrew from the
 main action.  The Church moved to disqualify the entire Los Angeles Superior
 Court and/or to transfer the action to another county on the ground the entire
 court was biased.  The motion was denied as well as the Church's *641 writ
 petition to the Court of Appeal.  The case was assigned to Judge Lopez and the
 Church filed a Code of Civil Procedure section 170.6 motion to disqualify
 him.  The action was assigned to Judge Swearinger for trial.  After ruling the
 Church was required to produce its auditing file, the Church filed an action in
 U.S. District Court against the judge and others claiming bias and prejudice.
 This federal case was dismissed.  (Church of Scientology v. Superior Court
 (U.S.D.C.C.D.Cal.1986), No. CV 86-1362.)  Later after the judge denied the
 Church's motion for non-suit on the intentional infliction of emotional
 distress cause of action, the Church filed a formal motion to disqualify him
 for cause, bias and prejudice, which motion was denied.
  Wollersheim declared that he had liquidated all of his assets, personally
 spent about $300,000, and gone more than $900,000 into debt, not including
 attorney fees, during the litigation of the main action and related litigation,
 over an 11 year period.
  Andre A. Anderson, the jury foreperson in the prior action, declared that
 "from the start of the trial up through the return of the verdict, there was no
 reference to nor comment, by any juror or by any other person in my presence,
 about the trial judge, the Honorable Ronald Swearinger, to the effect that his
 tires had been slashed, or that his dog had died, or that he was being followed
 or in any other way harassed or bothered by Scientology."  Antoinette Saldana,
 one of the court bailiffs present during the trial, declared that she, "as well
 as all court personnel, took precautions to ensure that no one discussed the
 case with members of the jury or with anyone outside the courtroom."  Also, she
 declared that she was never aware of any unfavorable beliefs or biases held by
 the judge against the Church, and the judge never mentioned any strange
 occurrences for which he suspected the Church was or might be responsible.  He
 did not mention that his tires were slashed.  He mentioned his dog had died but
 never suggested the Church might be responsible for the dog's death.
  Declarations of former members and officials of the Church, Gerald
 Armstrong and Vicki Aznaran, revealed the practices and policies of the Church,
 including its "fair game" doctrine and employment of litigation practices
 designed "to bludgeon the opposition into submission," as well as attacks
 against judges who rule against it.  The declaration of an attorney who had
 represented the Church (Joseph A. Yanny), submitted in an action brought by the
 Church against him and others, related aspects of the Church's "fair game"
 doctrine, including copies of exhibits to demonstrate "the Cult, according to
 **628 written policy, will use any means legal or illegal to *642 subvert
 and frustrate judicial process against them, and will willingly and knowingly
 abuse judicial process in order to attack perceived 'enemies.' "
  The Church opposed Wollersheim's motion to strike and requested sanctions
 against Wollersheim and his attorneys.  The Church contended Wollersheim's free
 speech and petition rights were not the subject of the complaint.  The Church
 argued that even if section 425.16 applied, the Church could establish the
 probability that it would prevail.
  To demonstrate that the Church could meet its burden of proof (which the
 Church contended was the production of "evidence demonstrating the existence of
 a material factual issue as to its claim ..."), the Church submitted the
 declaration of counsel, Paul F. Moore II, which had been submitted in support
 of the Church's application for a new trial in the prior action.  Moore had
 declared that on August 18, 1986, Terri Reuter confirmed that the facts
 discussed in an "attached declaration" were true but she said she would not
 sign any declaration because she did not want to do anything to jeopardize the
 verdict.  Ms. Reuter told him, he declared, that she knew that she and other
 members of the jury were being followed but she could not prove it and that
 within the last week she was told by some court personnel that the judge's
 tires had been slashed and his dog had been found dead.  "This was told to me
 in conjunction with our conversations about the trial and in particular in
 relation to Defendant's alleged practice of 'Fair Game.' "  There was no
 declaration of Terri Reuter attached to Moore's declaration submitted in this
 action.
  The Church also submitted the declaration of Eric M. Lieberman.  Lieberman
 declared he had been interviewed on March 10, 1992, by William Horne, a
 reporter for the American Lawyer and Horne told Jonathan Lubell and him that
 Judge Swearinger had told Horne he believed the Church had attempted to harass
 him during the course of the trial.  The Church also submitted an
 unauthenticated copy of the American Lawyer article by Horne, entitled "The Two
 Faces of Scientology," in which Judge Swearinger is quoted. [FN2]

      FN2. The article states:  "California superior court judge Ronald
     Swearinger, who presided over the Wollersheim trial, describes the case
     itself as anything but normal:  Church trial lawyer Cooley and his co-
     counsel, the late John Peterson, filed a number of unsuccessful 'writs and
     motions' throughout the trial in an attempt to halt it, according to Judge
     Swearinger.  Three days into the trial, the judge says, they moved for his
     disqualification based on 'some secret conversation I'd had with someone
     I'd never heard of.'  They also filed a Section 1983 federal civil rights
     action against both him and the judge who sat on the case prior to him,
     says Swearinger, on the theory that by allowing the case to go to trial,
     the judges were denying the church its civil rights.  (Cooley confirms that
     the Section 1983 action and the disqualification motion were filed.)
     [P] But Swearinger's recollections of the oddities of the Wollersheim
     case go beyond court filings:  'I was followed [at various times]
     throughout the trial ... and during the motions for a new trial,' the judge
     claims.  'All kinds of things were done to intimidate me, and there were a
     number of unusual occurrences during that trial.  My car tires were
     slashed.  My collie drowned in my pool.  But there was nothing overtly
     threatening, and I didn't pay attention to the funny stuff.' "  (William W.
     Horne, The American Lawyer, "The Two Faces of Scientology" (July, August
     1992) 75, 77, 78.)
     "At the trial Scientologists packed the courtroom and hallways of the
     courthouse and regularly interrupted the proceedings by protesting against
     alleged religious discrimination.  [P] 'I'd let the jury out, let the
     [protesters] blab on, and then let the jury back in,' says Judge
     Swearinger.  'It didn't bother me.'  Swearinger says he thought Cooley's
     histrionics were 'comical' rather than effective, and that he often caught
     the jury 'rolling their eyes' at Cooley's 'loud talk and hostility to
     opposing counsel and witnesses.'  The jury returned a $30 million verdict
     in July 1986;  $5 million in compensatory damages and $25 million in
     punitives."  (Id. at p. 78.)

  In addition, Barry Van Sickle, who represented Wollersheim in his defense of
 the appeal in the prior action, declared that on April 6, 1992, Judge
 *643 Swearinger expressed an interest in acting as a "facilitator" in
 resolving the Wollersheim matter, now that the Court of Appeal had issued
 its opinion.  On the judge's request, Van Sickle contacted the Church's counsel
 in charge of settlement matters, Mr. Drescher.  Drescher declared he spoke on
 the telephone with Judge Swearinger a day or two later, and the judge stated
 that at the time of new trial motions he considered the jury award should have
 been reduced in the fashion that the Court of **629 Appeal did, but that he
 did not do this because he was upset with Church counsel, whom Judge Swearinger
 called "Fooley."  "In particular, Judge Swearinger told me that he was angered
 by Mr. Cooley arguing to the Court before a packed gallery, including media,
 that the jury had been 'in the tank' and that there was no way that he would
 reduce that verdict after Mr. Cooley had raised those allegations for fear of
 validating them."
  The trial court stayed the proceedings, including discovery, pending a
 final ruling by the California Supreme Court on the petition for review of the
 prior action by the Church.  On July 15, 1993, the California Supreme Court
 dismissed the petition and remanded to Division Seven of the Second Appellate
 District.  Wollersheim reset his motion after the remittitur was issued and the
 opinion of the Court of Appeal became final.
  The parties submitted additional argument and documentation.  Wollersheim
 submitted the declaration of Steven Fishman, on parole for a conviction of mail
 fraud.  He was a former member who had been sued by the Church.  Fishman
 declared that in the late summer or early fall of 1986 another Scientologist
 told him that he had drowned a dog named "Duke" that belonged to a Judge
 Swearinger.  Fishman also declared that, as part of "Operation Wolly" he had
 been ordered to call up jurors in the Wollersheim case in the middle of the
 night and hang up on them.  He relayed details of *644 his involvement in
 raiding the trash dumpster of the law office of Charles O'Reilly.  He also
 reported that an "agent" had been assigned to work in O'Reilly's law office as
 a typist/clerk/receptionist, to copy legal briefs and to influence O'Reilly
 into forcing Wollersheim to accept a settlement from the Church.
  Wollersheim's counsel, Mark Goldowitz, declared that he had actively
 participated in the enactment of the anti-SLAPP legislation.  He traced the
 legislative history of Senate Bill 1264 of 1991-1992 Regular Session, which he
 contended demonstrated the intent to cover all lawsuits and other lawsuit-
 related communications as petition activity.
  The Church disputed Wollersheim's interpretation of the applicability of
 section 425.16.  The Church attacked the credibility of Fishman, submitting
 declarations containing statements which contradicted Fishman's.  In reply,
 Wollersheim submitted a supplemental declaration of Fishman, accusing the
 persons who said the statements in his declaration were false of lying.
  On March 30, 1994, the trial court granted the motion to strike the complaint
 "for the reasons set forth in Defendant's moving papers," and dismissed the
 action with prejudice.
  The Church appealed.  Thereafter, the trial court granted Wollersheim's motion
 for an award of attorney fees, pursuant to subdivision (g) of section
 425.16.  The Church appealed from that judgment and the two appeals were
 consolidated.
                                     ISSUES
  Does section 425.16 apply to this action?
  If it does, did the Church demonstrate there is a probability it would
 prevail?
  Did the trial court abuse its discretion in setting the amount of the award of
 attorney fees?
                                   DISCUSSION
  1. Section 425.16 provides a remedy for SLAPP suits.
  Section 425.16 is designed to protect citizens in the exercise of their
 First Amendment constitutional rights of free speech and petition.  It is
 California's response to the problems created by meritless lawsuits brought to
 harass those who have exercised these rights.
  *645 SLAPP suits have been defined as "... 'civil lawsuits ... that
 are aimed at preventing citizens from exercising their political rights or
 punishing those who have done so.'  (Canan & Pring, Strategic Lawsuits Against
 Public Participation (1988) 35 Social Problems 506.)"  (Wilcox v.
 Superior Court (1994) 27 Cal.App.4th 809, 815, 33 Cal.Rptr.2d 446.)  They are
 brought, not to vindicate a legal right but rather to interfere with the
 defendant's ability to pursue his or her interests.  Characteristically, the
 SLAPP suit lacks **630 merit;  it will achieve its objective if it depletes
 defendant's resources or energy.  The aim is not to win the lawsuit but to
 detract the defendant from his or her objective, which is adverse to the
 plaintiff.  (See, Wilcox v. Superior Court, supra, at pp. 815-817, 33
 Cal.Rptr.2d 446, and authorities cited therein.)
  California enacted section 425.16 to provide a procedural remedy to resolve
 such a suit expeditiously.  Section 425.16 provides, in relevant part, as
 follows:
  "(a) The Legislature finds and declares that there has been a disturbing
 increase in lawsuits brought primarily to chill the valid exercise of the
 constitutional rights of freedom of speech and petition for the redress of
 grievances.  The Legislature finds and declares that it is in the public
 interest to encourage continued participation in matters of public
 significance, and that this participation should not be chilled through abuse
 of the judicial process.
  "(b) A cause of action against a person arising from any act of that person in
 furtherance of the person's right of petition or free speech under the United
 States or California Constitution in connection with a public issue shall be
 subject to a special motion to strike, unless the court determines that the
 plaintiff has established that there is a probability that the plaintiff will
 prevail on the claim.  In making its determination, the court shall consider
 the pleadings, and supporting and opposing affidavits stating the facts upon
 which the liability or defense is based.
  "If the court determines that the plaintiff has established a probability that
 he or she will prevail on the claim, neither that determination nor the fact of
 that determination shall be admissible in evidence at any later stage of the
 case, and no burden of proof or degree of proof otherwise applicable shall be
 affected by that determination.
  "(c) In any action subject to subdivision (b), a prevailing defendant on a
 special motion to strike shall be entitled to recover his or her attorney's
 fees and costs.  If the court finds that a special motion to strike is
 frivolous or is *646 solely intended to cause unnecessary delay, the court
 shall award costs and reasonable attorney's fees to a plaintiff prevailing on
 the motion, pursuant to Section 128.5.
  "....
  "(e) As used in this section, 'act in furtherance of a person's right of
 petition or free speech under the United States or California Constitution in
 connection with a public issue' includes any written or oral statement or
 writing made before a legislative, executive, or judicial proceeding, or any
 other official proceeding authorized by law;  any written or oral statement or
 writing made in connection with an issue under consideration or review by a
 legislative, executive, or judicial body, or any other official proceeding
 authorized by law;  or any written or oral statement or writing made in a place
 open to the public or a public forum in connection with an issue of public
 interest.
  "(f) The special motion may be filed within 60 days of the service of
 the complaint or, in the court's discretion, at any later time upon terms it
 deems proper.
  "(g) All discovery proceedings in the action shall be stayed upon the filing
 of a notice of motion made pursuant to this section.  The motion shall be
 noticed for hearing not more than 30 days after service unless the docket
 conditions of the court require a later hearing.  The stay of discovery shall
 remain in effect until notice of entry of the order ruling on the motion.  The
 court, on noticed motion and for good cause shown, may order that specified
 discovery be conducted notwithstanding this subdivision...."
  [1][2][3] The moving party bears the initial burden of establishing a prima
 facie showing the plaintiff's cause of action arises from the defendant's free
 speech or petition activity.  (Wilcox v. Superior Court, supra, 27
 Cal.App.4th at p. 820, 33 Cal.Rptr.2d 446.)  "The defendant may meet this
 burden by showing the act which forms the basis for the plaintiff's cause of
 action was a written or oral statement made before a legislative, executive, or
 judicial proceeding...."  (Ibid.)  If the defendant establishes a prima
 facie case, then the burden shifts to the plaintiff to establish " 'a
 probability that the plaintiff will **631 prevail on the claim,' " i.e.,
 "make a prima facie showing of facts which would, if proved at trial, support a
 judgment in plaintiff's favor."  (Id. at p. 823, 33 Cal.Rptr.2d 446.)  In
 making its determination, the trial court is required to consider the pleadings
 and the supporting and opposing affidavits stating the facts upon which the
 liability or defense is based.  (s 425.16, subd. (b).)  Discovery is stayed
 upon the filing of the motion.  (s 425.16, subd. (g).)  However, upon
 *647 noticed motion and for good cause shown, the court may allow specified
 discovery. [FN3]

      FN3. The provisions of section 425.16 were designed to provide an
     economical and expeditious remedy to SLAPP suits.  The defendant may file a
     motion to strike within 60 days of the service of the complaint.  Because
     the motion is heard within 30 days of the notice of the motion, the
     plaintiff's case may not be developed.  However, the provision allowing
     discovery for good cause provides plaintiff a means to avoid any legitimate
     prejudice due to the alacrity of the proceedings.  Scientology did not file
     a motion to conduct additional discovery.

  2. The Church's action was properly subjected to a section 425.16 motion to
 strike.
  a. Section 425.16 applies to a cause of action arising from defendant's
 valid exercise of his petition rights, including litigation activities.
  [4] In accordance with the accepted principles of statutory interpretation,
 we first examine the language of the statute to determine the Legislature's
 intent.  If the language is clear and unambiguous there is no need to resort to
 other interpretative aids, such as the legislative history.  (Rojo v.
 Kliger (1990) 52 Cal.3d 65, 73, 276 Cal.Rptr. 130, 801 P.2d 373.)
  Section 425.16 applies to a cause of action against a person "arising from
 any act of that person in furtherance of the person's right to petition or free
 speech under the United States or California Constitution in connection with a
 public issue."  (s 425.16, subd. (b).)
  Subdivision (e) of section 425.16 expressly defines the First Amendment
 activity from which the subject cause of action arises as "includ[ing] [1] any
 written or oral statement or writing made before a legislative, executive, or
 judicial proceeding, or any other official proceeding authorized by law;  [2]
 any written or oral statement or writing made in connection with an issue under
 consideration or review by a legislative, executive, or judicial body, or any
 other official proceeding authorized by law;  or [3] any written or oral
 statement or writing made in a place open to the public or a public forum in
 connection with an issue of public interest."  (Emphasis added.)
  [5][6][7] The right of access to the courts is an aspect of the First
 Amendment right to petition the Government for redress of grievances.
 (McDonald v. Smith (1985) 472 U.S. 479, 482-484, 105 S.Ct. 2787, 2789-90, 86
 L.Ed.2d 384;  California Motor Transport Co. v. Trucking Unlimited (1972)
 404 U.S. 508, 510, 92 S.Ct. 609, 611, 30 L.Ed.2d 642;  Bill Johnson's
 Restaurants, Inc. v. NLRB (1983) 461 U.S. 731, 740, 103 S.Ct. 2161, 2168, 76
 L.Ed.2d 277;  see, *648 also, Matossian v. Fahmie (1980) 101 Cal.App.3d
 128, 135-137, 161 Cal.Rptr. 532.)  "The [United States Supreme Court]
 traditionally has held that the Due Process Clauses protect civil litigants who
 seek recourse in the courts, either as defendants hoping to protect their
 property or as plaintiffs attempting to redress grievances."  (Logan v.
 Zimmerman Brush Co. (1982) 455 U.S. 422, 429, 102 S.Ct. 1148, 1154, 71 L.Ed.2d
 265.) [FN4]  A cause of action "arising from" defendant's litigation activity
 may appropriately be the subject of a section 425.16 motion to strike.

      FN4. The right to petition is not absolute, providing little or no
     protection for baseless litigation or sham or fraudulent actions.  Under
     the statutory scheme, a motion to strike cannot be successful unless the
     plaintiff's action is a meritless attempt to interfere with the defendant's
     exercise of petition activity and it is shown it lacks merit.  Thus
     section 425.16 protects the defendant from retaliatory action for his or
     her exercise of legitimate petition rights but does not unconstitutionally
     interfere with the plaintiff's own petition rights.

  [8] The Church contends section 425.16 does not apply because its action
 against Wollersheim is not an attack on Wollersheim personally and would not
 interfere with Wollersheim's right to pursue his claims against the Church--
 i.e., the Church's complaint **632 does not "arise" from any act in
 furtherance of Wollersheim's right of petition or free speech because the
 Church does not challenge Wollersheim's right to file a lawsuit nor is its
 lawsuit "brought primarily to chill the valid exercise" of that right.
  The Church's approach to the interpretation of section 425.16 is too
 restrictive, suggesting that only a direct personal attack on the defendant
 would be subject to a motion to strike.
  The statutory language, however, is clear and unambiguous.  (Rojo v.
 Kliger, supra, 52 Cal.3d at p. 73, 276 Cal.Rptr. 130, 801 P.2d 373.)  It
 specifically applies to "[a] cause of action against a person arising from any
 act of that person in furtherance of the person's right of petition" including
 a "written or oral statement or writing made in connection with an issue
 under ... review by a ... judicial body...."  (s 425.16, subds. (b) italics
 added, and (e).)  And, thus, it literally applies to any direct attack on the
 judgment in the prior action, which resulted from Wollersheim's petition
 activity.
  [9][10][11] Furthermore, an examination of the history of the underlying
 litigation reveals that the instant action is consistent with a pattern of
 conduct by the Church to employ every means, regardless of merit, to frustrate
 or undermine Wollersheim's petition activity.  When a party to a lawsuit
 engages in a course of oppressive litigation conduct designed to discourage the
 opponents' right to utilize the courts to seek legal redress, the trial court
 may properly apply section 425.16.  We hold that in making that
 determination, the trial court may properly consider the litigation history
 between the *649 parties.  The legislative rationale in enacting the statute
 is consistent with such an analysis because acts which are designed to
 discourage the bringing of a lawsuit are no more oppressive than acts which
 seek to prolong the litigation to a point where it is economically
 impracticable to maintain and pursue it to a final conclusion.  When one party
 to a lawsuit continuously and unsuccessfully uses the litigation process to
 bludgeon the opponent into submission, those actions must be closely
 scrutinized for constitutional implications.
  In the instant action the Church's actions clearly fall within the
 ambit of section 425.16.  Among its other litigation strategies, the Church
 has filed two non-meritorious federal court actions as well as this one. [FN5]
 The Church has filed numerous appeals in state and federal courts and has
 prolonged Wollersheim's 1980 lawsuit for 15 years.  When the litigation actions
 of the Church are analyzed in the light of the entire litigation history
 between the parties it appears the instant lawsuit was brought by the Church
 against Wollersheim:  (a) in retaliation for his 1980 lawsuit against the
 Church;  (b) to punish him economically for bringing that lawsuit;  and (c) to
 obliterate the value of any victories over the Church by forcing him to abandon
 his efforts to recover the damages awarded in the prior action by making it too
 costly to do so. [FN6]

      FN5. Just prior to oral argument we were informed by counsel for
     Wollersheim that on August 21, 1995, Scientology filed still another action
     against Wollersheim in the Federal District Court of Colorado.  Wollersheim
     complains that through a civil writ of seizure in that action the Church
     has seized over 600,000 documents from Wollersheim and has used that
     lawsuit to conduct discovery as to Judge Swearinger, attorney Charles
     O'Reilly and Daniel Leipold, the trial judge and Wollersheim's past and
     present attorneys respectively in the prior action, in violation of the
     automatic stay order of section 425.16.  The Church objects to our
     considering the Colorado lawsuit on the grounds that it is irrelevant to
     the proceedings herein.  Inasmuch as we know nothing of the facts
     underlying that lawsuit we agree with the Church and decline to consider
     that lawsuit in this appeal.  We will leave the issue of whether that suit
     is meritorious to the Colorado courts.

      FN6. Wollersheim declares he has spent $300,000 and is indebted for
     another $900,000 as a result of his disputes with the Church.

  [12] The Church argues that it has every right to exhaust its legal
 remedies, including appeal rights.  We agree.  However, when a litigant
 continuously and unsuccessfully uses the litigation process in filing
 unmeritorious motions, appeals and lawsuits, such actions have constitutional
 implications which may be reviewed on a motion under section 425.16.
  **633 [13] The Church also argues it has been successful in its post trial
 motion and appellate strategy and therefore, even if the litigation history is
 considered, it *650 favors the Church.  We disagree.  The only relief the
 Church has obtained from all of its lawsuits, petitions for writs of mandate,
 appeals to the California Court of Appeal and the Ninth Circuit Court of
 Appeals, the California and the United States Supreme Courts was obtained in
 the initial state court appeal in 1989 which resulted in a reduction of
 Wollersheim's judgment.  The fact that both the California and the United
 States Supreme Courts granted the Church's petitions was no more than
 fortuitous as both courts at that time were reviewing the issue of punitive
 damages.  In each instance, however, the case was remanded to the intermediate
 appellate courts with no change in ruling.
  [14] The Church also argues that Wollersheim's tort action against a private
 party (the Church) was not a matter of public interest subject to the
 protection of section 425.16.  Subdivision (e), describing protected
 activity, refers to three categories;  only the category of activity referred
 to as the "exercise of free speech rights" is subject to the limitation that it
 be "made in a place open to the public or a public forum in connection with an
 issue of public interest." [FN7]  The first two categories parallel the
 description of privileged communications in Civil Code section 47,
 subdivision (b) and include judicial proceedings without any limitation as to
 subject matter. [FN8]

      FN7. See, e.g., (Wilcox v. Superior Court, supra, 27 Cal.App.4th at p.
     820, 33 Cal.Rptr.2d 446, citing Pacific Gas & Electric Co. v. Bear
     Stearns & Co. (1990) 50 Cal.3d 1118, 1136, 270 Cal.Rptr. 1, 791 P.2d 587.)
     The Bear Stearns court placed limits on the ability to bring a tort
     action against persons who brought an action or induced another to bring an
     action against plaintiff.  "If any person who induced another to bring a
     lawsuit involving a colorable claim could be liable in tort, free access to
     the courts could be choked off with an assiduous search for unnamed
     parties....  [I]t would defeat the purpose of assuring free access to the
     courts, and cause a flood of oppressive derivative litigation, to assess
     tort liability for their activities."  (Id. at p. 1136, 270 Cal.Rptr. 1,
     791 P.2d 587.)

      FN8. Civil Code section 47, subdivision (b) refers to privileged
     publication or broadcast made in any "(1) legislative proceeding, (2)
     judicial proceeding, (3) in any other official proceeding authorized by
     law, or (4) in the initiation or course of any other proceeding authorized
     by law and reviewable pursuant to Chapter 2 (commencing with Section 1084)
     of Title 1 of Part 3 of the Code of Civil Procedure ... [with certain
     exceptions thereafter listed]."

  [15] But even if we were to assume that a motion to strike pursuant to
 section 425.16 were limited to issues of public interest, the motion would
 apply to this action against Wollersheim, arising from his lawsuit against the
 Church.  Although matters of public interest include legislative and
 governmental activities, they may also include activities that involve private
 persons and entities, especially when a large, powerful organization may impact
 the lives of many individuals.  Examples are product liability suits, real
 estate or investment scams, etc.  (See Wilcox, supra, involving an
 *651 action against private entities.)  The record reflects the fact that
 the Church is a matter of public interest, as evidenced by media coverage and
 the extent of the Church's membership and assets.  Furthermore, the underlying
 action concerned a fundamental right, the constitutional protection under the
 First Amendment religious practices guaranties, and addressed the scope of such
 protection, concluding that the public has a compelling secular interest in
 discouraging certain conduct even though it qualifies as a religious expression
 of the Scientology religion.  (Wollersheim v. Church of Scientology, supra,
 212 Cal.App.3d at pp. 887-900, 260 Cal.Rptr. 331.)
  [16] The Church objects that the application of section 425.16 to
 any action arising from the defendant's exercise of petition rights through
 litigation would subject all counterclaims and other claims relating to a
 defendant's prior legal action to a special motion to strike.
  Although a cross-complaint may be subject to a section 425.16 motion, not
 all cross-complaints would qualify as SLAPP suits.  A defendant may file a
 cross-complaint against the plaintiff for any existing cause of action
 regardless of its nature and origins.  (s 428.10, subd. (a).)  Only those
 cross-complaints **634 alleging a cause of action arising from the
 plaintiff's act of filing the complaint against the defendant and the
 subsequent litigation would potentially qualify as a SLAPP action.
 (s 425.16, subds. (b) and (d).)  For example, a person may attempt to bring
 a SLAPP suit alleging that libelous allegations or statements were contained in
 the complaint itself.  However, because defendant's allegations are privileged
 communications under Civil Code section 47, the suit would be meritless.
 (See, e.g., California Physicians' Service v. Superior Court (1992) 9
 Cal.App.4th 1321, 12 Cal.Rptr.2d 95.)
  A compulsory cross-complaint on a "related cause of action" against the
 plaintiff (s 426.30, subd. (a)) would rarely, if ever, qualify as a SLAPP suit
 arising from petition activity.  By definition, a "related cause of action" is
 "a cause of action which arises out of the same transaction, occurrence, or
 series of transactions or occurrences as the cause of action which the
 plaintiff alleges in his complaint."  (s 426.10, subd. (c), emphasis added.)
 The SLAPP suit is not "related" to the transaction or occurrence which is the
 subject of the plaintiff's complaint, but arises out of the litigation process
 itself.
  *652 b. Section 425.16 applies to any cause of action arising from
 petition activity, not only tort actions.
  [17] The Church also argues section 425.16 applies to tort actions only.
 [FN9]

      FN9. The Church points to comments in the legislative history and language
     from Wilcox v. Superior Court (1994) 27 Cal.App.4th 809, 33 Cal.Rptr.2d
     446, regarding these particular aspects of SLAPP suits.  For example, in
     discussing SLAPP suits, Wilcox stated, "The favored causes of action in
     SLAPP suits are defamation, various business torts such as interference
     with prospective economic advantage, nuisance and intentional infliction of
     emotional distress.  Plaintiffs in these actions typically ask for damages
     which would be ruinous to the defendants.  [P] SLAPP suits are brought to
     obtain an economic advantage over the defendant, not to vindicate a legally
     cognizable right of the plaintiff."  (Id. at p. 816, 33 Cal.Rptr.2d 446,
     original italics, citations omitted.)  Nothing in Wilcox or the statute
     specifically limits the applicability of section 425.16 to tort actions
     only.  Furthermore, as Wollersheim correctly points out, the comments about
     tort actions are contained in documents which do not constitute legislative
     history.

  Considering the purpose of the provision, expressly stated, the nature or form
 of the action is not what is critical but rather that it is against a person
 who has exercised certain rights such as Wollersheim did in the prior action
 against the Church.  Although the "favored causes of action" in SLAPP suits may
 be defamation, various business torts, nuisance and intentional infliction of
 emotional distress (Wilcox, supra, at p. 816, 33 Cal.Rptr.2d 446), the
 Legislature did not limit application of the provision to such actions,
 recognizing that all kinds of claims could achieve the objective of a SLAPP
 suit--to interfere with and burden the defendant's exercise of his or her
 rights.
  The Church argues that "The legislature was especially concerned by the threat
 to the exercise of constitutional rights posed by a complaint demanding costly
 damages, which is likely to be a tort suit demanding punitive damages.  Thus,
 because of the possibility of punitive damages, a SLAPP suit in tort poses the
 greatest threat to the exercise of constitutional rights;  therefore, it was
 against these tort suits that the legislature directed its statutory remedy."
 Once again the Church's construction of the legislative intent behind
 section 425.16 is too restrictive.  There is no such limiting language in
 the statute.  Moreover, the free exercise of the constitutional right of
 judicial redress is no less threatened by the employment of non-tortious
 litigation practices designed to economically "bludgeon the opposition into
 submission."  In either case the result is to subject the litigant to economic
 loss sufficient to discourage the free exercise of a constitutionally protected
 right.
  Furthermore, the Church's argument that its complaint sought no relief
 or judgment directly against Wollersheim and therefore he would remain free
 *653 to assert and pursue his claims against the Church is equally
 misplaced.  The Church's complaint asserted that the judgment in the prior
 action should be declared null and void and a new trial should be ordered.  The
 effect of such an order would be to directly impact Wollersheim by requiring
 him to incur further economic hardship by relitigating a matter that
 **635 has already consumed 15 years of litigation;  a five month jury trial;
 at least two appeals and six writ petitions in the Court of Appeal;  two
 petitions for review in the California Supreme Court;  two petitions for
 certiorari in the United States Supreme Court and two lawsuits in Federal
 District Court, all arising out of Wollersheim's original 1980 lawsuit against
 the Church.
  3. The Church failed to establish the "probability" it would prevail on its
 claim.
  [18][19] Once the defendant has met the burden of establishing that
 section 425.16 applies to the lawsuit, the burden shifts to the plaintiff to
 establish "that there is a probability that the plaintiff will prevail on the
 claim."  (s 425.16, subd. (b).)  On appeal, we independently review the
 entire record to determine whether the Church made a sufficient prima facie
 showing that it would prevail in light of the applicable law relative to the
 claim.  (Cf., Robertson v. Rodriguez (1995) 36 Cal.App.4th 347, 357-358, 42
 Cal.Rptr.2d 464 [libel action which requires clear and convincing evidence of
 malice].)
  "In making its determination, the court shall consider the pleadings, and
 supporting and opposing affidavits stating the facts upon which the liability
 or defense is based."  (s 425.16, subd. (b).)
  [20] Wilcox held that the "probability" hurdle was met if the plaintiff
 demonstrated sufficient facts to establish a prima facie case, similar to the
 standard used in determining a motion for nonsuit or directed verdict.
 (Wilcox v. Superior Court, supra, 27 Cal.App.4th at p. 824, 33 Cal.Rptr.2d
 446.)  "To establish 'a probability that the plaintiff will prevail on the
 claim' the plaintiff must make a prima facie showing of facts which would, if
 proved at trial, support a judgment in plaintiff's favor."  (Id. at p. 823,
 33 Cal.Rptr.2d 446.)  The Wilcox court observed that the original version of
 Senate Bill No. 1264 required a "substantial" probability, but it was amended
 to eliminate the adjective.  (Id. at p. 824, 33 Cal.Rptr.2d 446.)
 Nevertheless, the court reasoned the Legislature did not intend a threshold
 lower than a "reasonable probability."  "Rather, it appears the Legislature
 eliminated the word 'substantial' in order to avoid the implication the trial
 court was to weigh the evidence which ... would raise a serious constitutional
 problem [regarding the preservation of the plaintiff's right to a jury
 trial].  [Citation.]"  (Id. at pp. 824-825, 823, 33 Cal.Rptr.2d 446.)
  *654 The court explained, "[T]he common features of SLAPP suits are their
 lack of merit and chilling of defendants' valid exercise of free speech and the
 right to petition the government for a redress of grievances.  Section
 425.16 was intended to address those features by providing a fast and
 inexpensive unmasking and dismissal of SLAPP's.  It is also presumed the
 Legislature intended to enact a valid statute.  Anti-SLAPP legislation,
 therefore, must be fast, inexpensive and constitutional or it is of no benefit
 to SLAPP victims, the court or the public.  In order to satisfy due process,
 the burden placed on the plaintiff must be compatible with the early stage at
 which the motion is brought and heard (s 425.16, subds. (f) and (g)) and the
 limited opportunity to conduct discovery (subd. (g)).  In order to preserve the
 plaintiff's right to a jury trial the court's determination of the motion
 cannot involve a weighing of the evidence."  (27 Cal.App.4th at p. 823, 33
 Cal.Rptr.2d 446, citations omitted, original italics.)
  [21][22] Subsequent appellate decisions have employed the standard
 applied in Wilcox.  (See, Evans v. Unkow (1995) 38 Cal.App.4th 1490,
 1496, 45 Cal.Rptr.2d 624;  Lafayette Morehouse, Inc. v. Chronicle Publishing
 Co. (1995) 37 Cal.App.4th 855, 867, 44 Cal.Rptr.2d 46, review den.;  Ludwig
 v. Superior Court (1995) 37 Cal.App.4th 8, 15, 43 Cal.Rptr.2d 350, review
 den.;  Robertson v. Rodriguez (1995) 36 Cal.App.4th 347, 355, 42 Cal.Rptr.2d
 464;  Dixon v. Superior Court (1994) 30 Cal.App.4th 733, 746, 36 Cal.Rptr.2d
 687, review den.)  It is recognized, with the requirement that the court
 consider the pleadings and affidavits of the parties, the test is similar to
 the standard applied to evidentiary showings in summary judgment motions
 pursuant to section 437c and requires that the showing be made by competent
 admissible evidence within the personal knowledge of the declarant.  (Ludwig
 v. Superior **636 Court, supra, at pp. 15-16, 43 Cal.Rptr.2d 350.) [FN10]
 Averments on information and belief are insufficient.  (Evans v. Unkow,
 supra, 38 Cal.App.4th at pp. 1493, 1497-1498, 45 Cal.Rptr.2d 624;  cf.
 College Hospital, *655 Inc. v. Superior Court (1994) 8 Cal.4th 704, 719,
 34 Cal.Rptr.2d 898, 882 P.2d 894 [construing Code Civ.Proc., s 425.13, which
 requires a motion to amend a complaint to state a punitive damages claim
 against a health care provider].)  As in a motion for summary judgment, the
 pleadings frame the issues to be decided.  (See, e.g., Dorado v. Knudsen
 Corp. (1980) 103 Cal.App.3d 605, 611, 163 Cal.Rptr. 477.)

      FN10. Wollersheim and amici curiae implore this court to apply a heavier
     burden of proof, contending that "probability" means "more likely than
     not."
     The legislative history reveals that the "probability" language was a
     compromise.  A predecessor bill to Senate Bill 1264 was drafted as a
     pleading bar, requiring plaintiffs to obtain prefiling approval of any
     lawsuit arising out of a defendant's exercise of First Amendment or
     petition rights.  Governor Deukmejian vetoed that bill.  (Wilcox v.
     Superior Court, supra, 27 Cal.App.4th 809, 820, 33 Cal.Rptr.2d 446.)
     Senate Bill 1264 originally contained a burden of proof requiring plaintiff
     to show a "substantial probability" of prevailing on the merits.  In
     response to opposition to that standard, the bill was amended to the
     "probability" standard.  The Legislature rejected a standard proposed by
     Governor Wilson:  "sufficient evidence upon which a reasonable claim may be
     based."  It is contended that the "probability" standard adopted was
     intended to require a plaintiff to show a "likelihood" or "51% chance" of
     prevailing.  The "legislative history" cited for this interpretation is a
     letter from the Governor's office which states that there appeared to be no
     meaningful distinction between the "substantial probability" standard and
     the "reasonable probability" standard then being proposed.  In criticizing
     that standard as "fundamentally unfair," the letter stated that it "would
     require a plaintiff to have 51% of his or her case proven the day the suit
     is filed and before any discovery is taken."  The bill's sponsor, Bill
     Lockyer, objected to the Governor's proposed standard, claiming it would
     "eviscerate the measure."  The Governor signed the legislation with the
     "probability" standard.
     In light of potential problems with the constitutional right to a jury
     trial, the courts have interpreted the plaintiff's burden in opposing a
     motion to strike pursuant to section 425.16 as requiring the
     demonstration of a prima facie case.  (Lafayette Morehouse, Inc. v.
     Chronicle Publishing Co., supra, 37 Cal.App.4th 855, 867, 44 Cal.Rptr.2d
     46.)  We are in accord with these authorities.

  Therefore, the Church was required to demonstrate by admissible evidence the
 probability that it would succeed in obtaining an injunction to set aside the
 former judgment in Wollersheim's favor on the ground of judicial bias during
 the conduct of the prior action.  This it failed to do.
  In order to establish the probability of success the Church had to present
 admissible evidence of judicial bias sufficient to void the judgment in the
 prior action.  Courts applying the former judicial disqualification statute,
 Code of Civil Procedure section 170, subdivision (a), held that judgments of
 a disqualified judge were void.  A void judgment is open to attack at any
 time.  (Cadenasso v. Bank of Italy (1932) 214 Cal. 562, 567-568, 6 P.2d
 944.)  However, courts applying the new provisions, Code of Civil Procedure
 section 170, et seq., adopted in 1984, consider such judgments or orders merely
 voidable.  (Betz v. Pankow (1993) 16 Cal.App.4th 931, 939-940, 20
 Cal.Rptr.2d 841, and cases cited therein.)
  Section 170.1, subdivision (a)(6) provides for the disqualification of a judge
 if "For any reason ... (B) the judge believes there is a substantial doubt as
 to his or her capacity to be impartial, or (C) a person aware of the facts
 might reasonably entertain a doubt that the judge would be able to be
 impartial.  Bias or prejudice towards a lawyer in the proceeding may be grounds
 for disqualification."
  [23][24] "The matter of disqualification should be raised when the facts
 constituting the grounds for disqualification are first discovered and, in any
 event, before the matter involved is submitted for decision.  (Baker v.
 Civil Service Com. (1975) 52 Cal.App.3d 590, 594, 125 Cal.Rptr. 162 [ ].)  This
 rule applies, however, only when the facts constituting the disqualification
 are discovered before a *656 case is submitted for decision.  The rule rests
 on the principle that a party may not gamble on a favorable decision.
 (Ibid.) ...  [C]ase law recognizes situations in which a party is entitled
 to relief even though the grounds for disqualification are not discovered until
 after judgment is entered.  In such **637 case, a statement of
 disqualification is timely if submitted at the 'earliest practicable
 opportunity' after the disqualifying facts are discovered."  (Urias v.
 Harris Farms, Inc. (1991) 234 Cal.App.3d 415, 424-425, 285 Cal.Rptr. 659
 [summary judgment granted by disqualified judge held to be voidable] review
 den.) [FN11]

      FN11. Wollersheim's contention that the Church's complaint is an
     unsuccessful attempt to allege either intrinsic or extrinsic fraud is
     somewhat beside the point.  Rather the complaint is an attempt to allege
     the judgment in the underlying action is void because the matter was tried
     before a judge who concealed his bias.  Nevertheless, the Church failed to
     successfully plead or present evidence in opposition to Wollersheim's
     motion to support the essential basis for such a claim--facts of Judge
     Swearinger's alleged bias during the trial.

  In making our determination whether the Church has established a
 probability that it would prevail, we now consider "the pleadings, and
 supporting and opposing affidavits stating the facts upon which the liability
 or defense is based," (s 425.16, subd. (b)), as discussed above.
  [25][26][27] An examination of the Church's complaint reveals an absence of
 any admissible evidence to demonstrate its claim.  The allegations of fact in
 the complaint which are critical to the Church's claim of judicial bias are not
 admissible, even though the complaint is verified, because they were not within
 the personal knowledge of the verifier, the President of the Church.
 Generally, a party cannot simply rely on the allegations in its own pleadings,
 even if verified, to make the evidentiary showing required in the summary
 judgment context or similar motions, such as plaintiff's motion to amend to
 include a punitive damage claim under section 425.13, subdivision (a).
 (College Hospital Inc. v. Superior Court, supra, 8 Cal.4th at p. 720, fn. 7,
 34 Cal.Rptr.2d 898, 882 P.2d 894.)  The same rule applies to motions under
 section 425.16.  Here like motions under 437c, the pleadings merely frame the
 issues to be decided.  Similarly, an averment on information and belief is
 inadmissible at trial, and thus cannot show a probability of prevailing on the
 claim.  (Evans v. Unkow, supra, 38 Cal.App.4th at pp. 1497-1498, 45
 Cal.Rptr.2d 624.)  "An assessment of the probability of prevailing on the claim
 looks to trial, and the evidence that will be presented at that time.  (See
 Wilcox v. Superior Court, supra, 27 Cal.App.4th at p. 824, 33 Cal.Rptr.2d
 446 [ ].)  Such evidence must be admissible.  (Id. at p. 830, 33 Cal.Rptr.2d
 446.)"  (Id. at p. 1497, 45 Cal.Rptr.2d 624, original italics.)
  Wollersheim made a number of objections to the evidence the Church offered by
 declarations.  Wollersheim's objections to portions of the declaration of Paul
 Moore on the grounds they were hearsay (Evid.Code, s 1200) *657 and
 irrelevant (Evid.Code, s 351) are properly sustained.  Mr. Moore refers to a
 statement of juror Terri Reuter, which showed on its face that she did not
 learn of the allegations concerning the judge's tires being slashed and the
 death of his dog until long after the verdict.  Also Moore's report of her
 statements regarding statements of court personnel were inadmissible double
 hearsay.  The declaration of Ms. Reuter to which Moore referred was not
 attached and was reportedly unsigned and never served on Wollersheim's counsel.
  Wollersheim also properly objected to the declaration of Eric Lieberman, which
 consists of his statement about the statements of the reporter, Mr. Horne,
 regarding the statements made by the judge to Mr. Horne.  This is inadmissible
 double hearsay.  (Evid.Code, s 1200.)
  Wollersheim objected to the declaration of Earle Cooley as irrelevant.  It
 simply states that the judge never mentioned to Church counsel that his tires
 had been slashed or that his collie had drowned in his pool, and that the judge
 did not "reveal his belief or concern" that Church personnel were responsible
 for acts of harassment.  Although Cooley's declaration may have some relevance
 to the issue of "discovery" of the alleged "new evidence" of bias, it contains
 no evidence of bias on the part of the judge.
  Wollersheim also properly objected to statements in the declaration of
 Barry Van Sickle on the grounds of hearsay, untrustworthiness and relevancy.
 The declaration contains hearsay evidence of statements of the judge made six
 years after the trial in the prior action to one of Wollersheim's
 appellate **638 counsel.  The judge is reported to have said that he was
 willing to act as a facilitator to settlement as he did not want to see the
 case retried.  These statements are irrelevant to the Church's claim of the
 existence of judicial bias during the trial itself.
  The declaration of William T. Drescher also contains hearsay and multiple
 hearsay, relaying the statements of Judge Swearinger to him and the statements
 of Van Sickle regarding the judge's comments to him six years after trial and
 Wollersheim objected on that basis.  The Church contends the statements are
 admissible under the state-of-mind exception.  Wollersheim also objected to
 these statements as irrelevant to the Church's claim of bias at the time of
 trial and that objection is sustainable.
  The unauthenticated copy of the American Lawyer article does not contain any
 competent evidence, as it too is multiple hearsay--the statements of Horne of
 the statements of Judge Swearinger.  Furthermore, the quoted statements of the
 judge which indicate that he believed "funny stuff" *658 was occurring also
 indicate he did not "pay attention" to it.  Therefore it is irrelevant, as
 Wollersheim contended.
  In opposition to the Church's "evidence," Wollersheim submitted substantial
 admissible evidence that the jury members had no knowledge that the judge's
 tires were slashed or that his dog had died.  There is evidence by declarations
 of court personnel that they were unaware of any bias on the part of the
 judge.  Terri Reuter declares that she learned of the tire slashing and dog
 drowning "sometime well after the trial in the Wollersheim case was over."
  Finally, we turn to the issue of the timeliness of the Church's lawsuit to set
 aside the verdict.  An action to void a judgment based on judicial bias is
 timely if filed at the " 'earliest practicable opportunity' after the
 disqualifying facts are discovered."  (Urias v. Harris Farms, Inc., supra,
 234 Cal.App.3d at p. 425, 285 Cal.Rptr. 659.)  Here the Church also failed in
 carrying its burden.  In its 1986 motion for new trial the Church raised the
 issue of Judge Swearinger's alleged bias and the possible contamination of the
 jury by Terri Reuter's unsigned declaration.
  The Church's numerous claims of judicial and jury bias and prejudice were
 adjudicated at earlier stages of the litigation.  Yet the Church waited seven
 years to file the instant lawsuit alleging the same facts to support its
 complaint.  Clearly the Church is too late.
  The trial court acted properly in granting Wollersheim's motion to strike the
 Church's complaint.  This conclusion did not require weighing evidence as the
 Church failed to present a prima facie case supported by admissible evidence.
 This conclusion also obviates the need to address the various credible,
 potentially meritorious, defenses of laches, unclean hands and collateral
 estoppel presented by Wollersheim, except to observe that such defenses are to
 be considered if necessary in determining plaintiff's probability of success
 once the plaintiff has presented evidence of the probability of success.
 (s 425.16, subd. (b).)
  4. The award of attorney fees was proper and supported by substantial
 evidence.
  [28] Upon the motion of Wollersheim, the trial court awarded attorney
 fees pursuant to section 425.16, subdivision (c) in the amount of
 $130,506.71.  In doing so, the trial court rejected Wollersheim's request to
 double the "lodestar" amount, the number of attorney hours expended multiplied
 by the hourly rates.  (See Serrano v. Priest (1977) 20 Cal.3d 25, 141
 Cal.Rptr. 315, *659 569 P.2d 1303.)  The Church contends the total number of
 hours claimed was unreasonable and inexplicable, pointing out that the case was
 dismissed on the basis of pleadings and accompanying declarations.
  [29][30][31] " 'The matter of reasonableness of attorney's fees is within
 the sound discretion of the trial judge.  [Citations.]  Determining the weight
 and credibility of the evidence, especially credibility of witnesses, is the
 special province of the trier of fact.  [Citation.]'  [Citation.]  'In
 determining what constitutes a reasonable compensation for an attorney who has
 rendered services in connection with a legal proceeding, the court may and
 should consider "the nature of the litigation, its difficulty, the amount
 involved, the skill required and the skill employed in **639 handling the
 litigation, the attention given, the success of the attorney's efforts, his
 learning, his age, and his experience in the particular type of work
 demanded ...;  the intricacies and importance of the litigation, the labor and
 necessity for skilled legal training and ability in trying the cause, and the
 time consumed."  [Citations.]'  [Citations.]"  (Stokus v. Marsh (1990) 217
 Cal.App.3d 647, 656-657, 266 Cal.Rptr. 90.)
  We find the trial court did not abuse its discretion in awarding attorney fees
 and that substantial evidence supports the award.  Wollersheim's counsel
 submitted declarations of their experience and expertise providing information
 supportive of the rates charged by counsel as well as itemized accountings of
 attorney time.  Wollersheim also submitted the declaration of an expert on
 attorney fees who opined that the rates requested by his counsel were "well
 within the range of market rates charged by attorneys of equivalent experience,
 skill and expertise."  The Church has not presented any evidence in the record
 that the award was based upon unnecessary or duplicative work or any other
 improper basis.
  5. Wollersheim is entitled to an award of attorney fees on appeal.
  [32] Wollersheim has asked this court to award him attorney fees on this
 appeal.  Subdivision (c) of section 425.16 provides for an award of attorney
 fees to the defendant who successfully brings a motion to strike.
  [33] "A statute authorizing an attorney fee award at the trial court level
 includes appellate attorney fees unless the statute specifically provides
 otherwise.  (Morcos v. Board of Retirement (1990) 51 Cal.3d 924, 927-929,
 275 Cal.Rptr. 187, 800 P.2d 543 [ ];  Grade-Way Construction Co. v. Golden
 Eagle Ins. Co. (1993) 13 Cal.App.4th 826, 837-838, 16 Cal.Rptr.2d 649
 [ ].)"  (Evans v. Unkow, supra, 38 Cal.App.4th at pp. 1499-1500, 45
 Cal.Rptr.2d 624.)  Section 425.16, subdivision (c) provides that a
 prevailing defendant is entitled to recover attorney fees and costs, and does
 not preclude recovery on appeal.  (Id. at p. 1500, 45 Cal.Rptr.2d 624.)
  *660 Wollersheim is awarded his attorney fees on this appeal, the
 amount of which is to be determined by the trial court upon remand.
                                   DISPOSITION
  Judgment of dismissal and judgment awarding attorney fees are affirmed.
 Wollersheim is awarded costs and attorney fees on appeal.  The matter is
 remanded to the trial court to determine the amount thereof.

  KLEIN, P.J., and CROSKEY, J., concur.

End of file...