I, Kim Mauzy, pursuant to Rule 80(c) of the Arizona Rules of Civil Procedure, hereby declare as follows.

1. I have personal knowledge of the facts set forth in this Declaration. I declare under penalty of perjury that the facts in this Declaration are true and correct.

2. I am one of the defendants in this lawsuit. The Church of Jesus Christ of Latter-day Saints (the “Church”) refers to local congregations as “Wards.” The issues in the lawsuit center on the Bisbee Ward located in Bisbee, Arizona. The Bisbee Ward is one of several Wards in a larger ecclesiastical unit (called a “Stake”) based in Sierra Vista, Arizona.

3. Each ward is led by a clergyman called a “Bishop.” John Herrod, who is also a defendant in this lawsuit, served as the Bishop of the Bisbee Ward from 2004 to 2012. I followed him and served as the Bishop in that Ward from 2012 to 2018.

4. From approximately 2009 to 2013, the Plaintiff children attended the Bisbee Ward church services with their parents.

5. The Church believes in the fundamental Christian doctrines of confession and repentance. The Church provides a Handbook to Bishops that contains guidance on Church policies and procedures. The Handbook in place while I was Bishop stated: “Repentance requires that all sins be confessed to the Lord.... Members should also confess to [the bishop] if they have committed serious sins.” Handbook 1 (2010) § 6.3.

6. The Handbook also stated: “Bishops ... have a responsibility to help members overcome transgression through repentance. This responsibility includes counseling with individual members as needed and helping them in their efforts to repent.” Handbook 1 (2010) § 6.1.

7. Church doctrine requires Bishops to keep confessions, counseling, and interviews confidential:

Bishops ... have a solemn duty to keep confidential all information that members given them in confessions and interviews. The same duty of confidentiality applies to all who take part in Church disciplinary councils .... Confidential information must not be shared with anyone except authorized ecclesiastical leaders.

Handbook 1 (2010) § 6.5.

During and after their term of service in a calling, leaders must keep confidences about matters discussed when interviewing and counseling. A breach of confidence can damage trust, testimonies, and faith. A leader must not discuss confidential matters with others ... unless he receives consent from the person he is interviewing or counseling.

Handbook 1 (2010) § 7.3.

8. When I became Bishop of the Bisbee Ward in 2012, as authorized by Church doctrine, Bishop Herrod shared with me in confidence information he had received in confidence from Paul Adams.

9. It is common for a Bishop to share confidential information about a Ward member with the succeeding Bishop in order to ensure that ministry, counseling and other religious issues are properly dealt with by the succeeding Bishop. Such communications are strictly confidential.

10. In August 2013, based on the information Bishop Herrod shared with me, I conducted a confidential Church disciplinary proceeding involving Paul Adams. Such proceedings are part of the repentance process under Church doctrine and are considered strictly confidential. The Church Handbook says that “all who take part in Church disciplinary councils” have a “solemn duty to keep all information” from the council confidential. Handbook 1, 2010 § 6.5.

11. The council was based on certain confidential information I received in my role as Bishop regarding Paul Adams. To a very limited extent, I involved Leizza Adams in that Church disciplinary proceeding and had confidential communications with her in my role as Bishop. I considered any and all information disclosed to me by Paul Adams and Leizza Adams regarding the reasons for such discipline to have been shared with me in my role as Church clergy and to be confidential within the dictates of my religion.

12. As a result of that confidential disciplinary proceeding, I made the decision to excommunicate Paul Adams from the Church.

13. All of the information I knew about any misconduct by Paul Adams was the result of confidential communications I received in my role as Bishop in the course of the discipline enjoined by the Church. I have always believed that maintaining these communications in confidence is reasonable and necessary within the concepts of my religion. Thus, I have never violated that confidence.

14. Indeed, I understand that Church doctrine and Arizona law required me as Bishop to maintain in confidence the confidential communications I received from Bishop Herrod and from Paul and Leizza Adams, including communications during the Church disciplinary proceedings related to Paul Adams.

15. After Paul Adams was excommunicated, the Plaintiff children continued to attend Church services with their mother, Leizza Adams, until Paul’s arrest in 2017. Although excommunicated, Paul Adams was allowed to attend, but he rarely did.

16. I never observed Paul Adams abusing or behaving inappropriately in any way toward his children, nor did I see any physical indications or visible signs that he was abusing them.

17. I did not know that Paul Adams was abusing his children while I was Bishop until he was arrested in 2017. The communications with me were about a past one-time incident (and other conduct by Paul Adams that gave rise to his excommunication). I did not know until Paul Adams was arrested in 2017 that he had abused Plaintiffs John Doe or Jane Doe II. I did not know until he was arrested that he had viewed or disseminated child pornography, including videos of his own children.

18. After Paul Adams was arrested in 2017, on July 9, 2018, Agent Edwards arrived at my home unannounced. He asked me, “Did Bishop Herrod kind of give you a heads-up about what was going on?” Without disclosing the substance of what Bishop Herrod had shared with me in confidence, I responded, “Gave me, yeah, a little bit of heads- up about what was going on.”

19. I was trying to be careful in what I said, but I felt obligated to respond. I should not have done so. Even though Paul Adams was dead and his misconduct had already come to light, I still had a duty to maintain the confidentiality of the communications I received. I had never been questioned by law enforcement before and felt intimidated and obligated to respond. My limited disclosure did not include the substance of any confession or confidential information that I had received from Paul Adams or Leizza Adams, and I attempted to explain to Agent Edwards that I could not discuss with him such substance because it was confidential.

20. I also shared with Agent Edwards information regarding Paul Adams that I first learned from press reports after Paul Adams was arrested.

21. At all times before and since that interview with Agent Edwards, I have maintained in confidence the confidential communications I received in my role as Bishop from and regarding Paul Adams.

22. “Relief Society” is the organization for all adult women in a Ward. In the Bisbee Ward, the Relief Society consists of about 20 to 30 women, and it normally meets on Sundays.

23. Almost every participating Relief Society member in a Ward is given an assignment to serve as a “visiting teacher” (now known as a “ministering sister”). A “visiting teacher” is invited to periodically interact with other Relief Society members to help strengthen their faith in Jesus Christ and offer them encouragement, help, and love. These interactions sometimes occur in-person at a Relief Society member’s home, but they often occur by phone call or text message.

24. I am not aware of any instance before Paul Adams’ arrest in February 2017 when any Relief Society member indicated any awareness, or even suspicion, that Paul Adams had abused his children.