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1PLAINTIFF
’S COMPLAINT
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BARRY VAN SICKLE - BAR NO. 986451079 Sunrise AvenueSuite B-315Roseville, CA 95661Telephone: (916) 549-8784E-Mail: bvansickle@surewest.netAttorney for PlaintiffCLAIRE HEADLEY
SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELESCLAIRE HEADLEY
,Plaintiff,vs.
CHURCH OF SCIENTOLOGYINTERNATIONAL, a corporateentity, RELIGIOUS TECHNOLOGYCENTER, a corporate entity ANDDOES 1 - 20
 Defendants.))))))))))))
PLAINTIFF
’S COMPLAINT FOR:
 1)
 
UNFAIR PRACTICES UNDER B&P §17200 ET. SEQ2)
 
DISCRIMINATIONINTRODUCTION
1)
 
This case is
brought to challenge Scientology’s
longstanding refusal to comply with various laws, including stateand federal labor laws. In addition to suffering illegal workingconditions and wages, Plaintiff was ordered and coerced to have
abortions by Defendants’ management. Plaintiff had to
terminatepregnancies to keep her position and small income
as Defendants’
servant. Defendant Scientology enterprises do not want employeesmissing time for babies and maternity leave.
 
 
2PLAINTIFF
’S COMPLAINT
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2)
 
The U.S. Supreme Court, the California Supreme Courtand the Ninth Circuit Court of Appeals, have issued opinions
supporting plaintiff’s
case. Defendants are subject to laborlaws and other neutral laws of general applicability. The goalsof this case include stopping the practice of ordering femaleemployees to have abortions, and clearing the path for workers ofScientology organizations to obtain the compensation due themunder state and federal labor laws. Plaintiff also seeks paymentfor her work at minimum wage and overtime rates.3)
 
Defendant Church of Scientology International (CSI)
represents itself to be the “Mother Church” of Scientology. CSI
has its principal office and apparent headquarters in LosAngeles, California. The County of Los Angeles is an appropriatevenue for this action. Religious Technology Center (hereinafter
“RTC) purports to be the owner or managing agent for various
copyrights and trademarks allegedly owned by the Scientologyenterprise.4)
 
Religious Technology Cen
ter (hereinafter “RTC”)
purports to be a California non-
profit corporation. RTC’s role
in the Scientology enterprise is to supposedly control access and
use of L. Ron Hubbard’s intellectual property interests. RTC is
the alleged owner or managing agent for various copyrights,trademarks or other intellectual property interests allegedlyowned by, or licensed to, the Scientology enterprise.5)
 
Plaintiff Claire Headley worked for defendants at belowminimum wage compensation from 1991 to 2005. Plaintiff
’s wor
kduties were clerical, commercial or secular in nature. Plaintiffis currently a resident of Los Angeles, California.
 
 
3PLAINTIFF
’S COMPLAINT
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6)
 
At times herein material, and continuing, DefendantsCSI and RTC were and are enterprises conducting business, andemployers paying employees to conduct said business, within theState of California and in interstate commerce. Accordingly,said Defendants are subject to California and Federal lawsconcerning their work force, working conditions, businesspractices, minimum wage, payment for overtime and the protectionof minors. As alleged in more detail herein, Defendants havesystematically ignored and violated said laws to the damage ofPlaintiff Headley and others similarly situated.7)
 
Plaintiff is uncertain with respect to the identity ofall persons or entities responsible and liable for this wrongfulconduct and names said potential parties as Doe Defendants asauthorized by California law.8)
 
Defendants CSI and RTC, related Scientology entitiesand potential Doe Defendants, apparently claim that workers suchas Plaintiff are not entitled to the benefits and protections of
law including the labor laws. Defendants’ claim to be above the
law in the name of religion is without merit. The question of
Scientology’s status as a bona fide rel
igion is subject to
serious dispute, especially when one studies Scientology’s
history of adopting a religious cloaking to avoid governmentalregulation and scrutiny,
and L. Ron Hubbard’s early writings
disclaiming religious status, however, the religion issue is notdispositive of
Scientology’s claim to be free of most legal
obligations. The weight of authority is contrary to Defendant
s’
self-granted immunity from state and federal labor laws. As
stated by the California Supreme Court, “ to permit religi
ous
of 00

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johnd0857

This attorneys points of authority are wrong, and most of his citations are not applicable. The cases he cited are from federal courts, and not in the 9th district fed. He cites Catholic Charities which is not correct because it was not a charitable organization. He cites Mitchell which is a fed appls case on fed law, although his complaint is a cal case. Cortez although applicable to for-profit companies is not valid here. Prince v. Mass is possibly a valid point as it is a US supreme court case, but only relates to Massachusetts and selling books on public streets, here again is a very broad application of that case, there is no CA law against having children sell books. Alamo case is not on point because RTC does not compete with other RTC's or other business in the publishing and distribution of church materials. Calvig is not on point, it deals with a Jesuit priest being sexually harassed by homosexual priests, and then being fired. north coast is off point it is about someone who has insurance trying to sue to get infertility procedures. This case should be removed as many of these citations have no mandatory authority on a CA trial court as they are federal based or wrong states codes which don't apply.

reply04 / 23 / 2009
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