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LAWRENCE LEVYLYLE FRANCIS MIDDLETONAttiprneys at Law14724 Ventura Boulevard, Suite 704Sherman Oaks, California 91403Tel. (818) 905-5971ATTORNEYS FOR: PlaintiffsSUPERIOR COURT FOR THE STATE OF CALIFORNIACOUNTY OF LOS ANGELESMANFRED STANSFIELD-, VALERIE STANSFIELD,FRANKLIN FREEDMAN, MARY MAREN, HANAELTRINGHAM WHITFIELD, JERRY WHITFIELD,and FREEDOM FOR ALL IN RELIGION(F.A.I.R.), a California Non-ProfitOrganization, individually and onbehalf of all others similarly
situated,
Plaintiffs,vsNORMAN STARKEY, Administrator of theEstate of L. RON HUBBARD,' The Estateof L. RON HUBBARD; CHURCH OF SPIRITUALTECHNOLOGY, a California Non-ProfitOrganization; CHURCH OF SCIENTOLOGY OFCALIFORNIA, a California Non-ProfitCorporation,' CHURCH OF SCIENTOLOGYADVANCED ORGANIZATION OF LOS ANGELES,a California Non-Profit Corporation,*CHURCH OF SCIENTOLOGY AMERICAN SAINTHILL ORGANIZATION, a California Non-Profit Corporation; CHURCH OF SCIENTOLOGY OF SAN FRANCISCO, a CaliforniaNon-Profit Organization,- CHURCH OFSCIENTOLOGY FLAG SERVICES ORGANIZATION,a Florida Non-Profit Corporation; MARYSUE HUBBARD? AUTHOR SERVICES, INC., aCalifornia for profit Corporation;RELIGIOUS TECHNOLOGY CENTER, a California Non-Profit Religious Corporation-; • "DAVID MISCAVIGE,' ANN BROEKER,*
PAT BROEKER/ SHERMAN LENSKE; VICKIAZNARAN; HEBER JENTZSCH; KEN HODEN;OFFICE OF SPECIAL AFFAIRS; BRIDGE PUB
LICATIONS; INC. , PUBLICATIONS ORGANI-
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CASE N°.:CLASS ACTION1. FRAUD2. BREACH OF AFIDUCIARY RELATIONSHIP OR
DUTY
3. INJUNCTIVE RELIEF AND CONSTRUCTIVE TRUST
 
ZATION, INC.; CHURCH OF SCIENTOLOGYCELEBRITY CENTER INTERNATIONAL, INC.;CHURCH OF SCIENTOLOGY OF LOS ANGELES,INC.; JOHN PETERSON; LYMAN SPURLOCK,"TERRI GAMBOA; MARC YAGER/ RAY MITHOFF,'and DOES I THROUGH 100, INCLUSIVE;Defendants.1Plaintiffs named in the caption of this Complaint areall residents of Los Angeles County, State of California.2Defendants are individuals and corporate entities eitherduly organized or existing under the laws of California withprincipal place of business in the City of Los Angeles, Countyof Los Angeles, California
r
or foreign corporations and individuals doing business in the City of Los Angeles, County of LosAngeles, California.3Plaintiffs do not know the true names and capacities ofdefendants sued herein as DOES I to 100, inclusive, and therefore sues them by such fictitious names. Plaintiffs will amendthis Complaint to allege their true names and capacities whenascertained. Plaintiffs are informed and believe that each ofthe fictitiously named defendants is responsible in some mannerfor the occurrences herein alleged, and that plaintiffs
1
damagesas herein alleged were proximately caused by such occurrences.Further, plaintiffs are informed and believe that said defendantsand each of them are agents and employees of each other and atall relevant times mentioned herein were acting within the courseand scope of that employment with the consent, permission and
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authority of each other.4
INTRODUCTION
Plaintiffs are suing individually on his or her ownbehalf and, collectively, on behalf of all persons similarlysituated. The class which plaintiffs represent is composed ofpresent or former members of the Church of Scientology. Thesemembers constitute a large class of individuals in like circumstances and like claims against the defendants. At this time,approximately 400 individuals have associated with the hereinnamed plaintiffs for the purpose of bringing this class action.Plaintiffs estimate that there are several thousand other individuals who are similarly situated as they are and with similarclaims against these same defendants. Together
 ,
they representa substantial number of the membership of the Church of Scientology. The persons in the class are numerous, consisting ofseveral thousand individuals, that the joinder of all suchpersons is impracticable and that the disposition of plaintiffs
1
claims in a single class action is a benefit to the parties andto the court.5There is a well-defined community of interest in thequestions of law and fact involved in this cause affecting theparties to be represented in that:a. fraudulent representations have been made bydefendants concerning their tax-exempt status andcharitable nature, concerning the manner by whichmoneys were obtained and received by L. Ron Hubbardand defendants named herein, concerning the confi-
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