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NN NV Peet v RainbowCanyon 312 Cv 00684 LRH Wgc 2013-01-02 Abuse of Minor Complaint Ocr

NN NV Peet v RainbowCanyon 312 Cv 00684 LRH Wgc 2013-01-02 Abuse of Minor Complaint Ocr

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01/05/2013

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7
8
Case 3:12-cv-00684-
LRH
-
WGC
Document1·2 Filed
01
/02/13Page3 of19
Case
No.
VV-
\"2.-\.
\ \
L.\
-:t
DeptNo.
0\
20
12
N
OV
21Ptl
3:
59
LINDA
WH
I
TE
PI"'
'""'
'
BY--!<:
!f.~l::-'--
IN
THE
SEVENTH )UDJCIAL
DISTRICT
CO
U
RT
STAT!':
OF
NE
VAD
A,
CO
UNTY
OP
W
HITE
PINE
MARK
AND
NJC
O
LB
P66T,
&L_
___
...J
PLA
lNTIPFS,
C!
VIJ,
COMI'I.AINT
10
vs.
.
~
~
l'IIIRCONON
FRBSH START:
RAINBOW
CANYON
RETR.6AT
,
~
~
11
RAIN80W
CANYON
R6COV6RY,
AHD
~
i~~
DOES
I·
X,
AND
DOSS,
INC.
1-10
£;~~
12
DEPeNDANT.
~
~
1
~
13
1
1--::C
- : -
om
: : : - :
e-: : n-::o
~ w ~ M ~ A ~ R = K ~ A
~ N= - o ~ N = t c :o - : : L E : - : .
P::s:::er
:,
-:a:n:d
L
;:
_=_
= 
~
-
-_ _
.JI
by
andthrough their attorney
of
record,
~a~
Ul
<
14
Richard
W.
Sears, of
SEARS
L
Aw
FI
RM,
LTD.
and
as
and
f
or
causeofacti
on
against said Defendants
a
-
15
complainandallege
as
follows:
16
1.
At
all
timesmentioned herein, Plaintiffs
are
residents
of
Broom
County,
State of
New
17
York.
18
2.At
all
times mentioned herein,Defendant's business islocatedin
LincolnCounty,
State
19
of
Nevada
.
20
3.
Thetruenamesof Defendants
DOES
f
through X
Inclusive,
whetherindividual.
21
co
rporate, associate,
or
otherwiseare unknown
to
thePlai
ntiff,
who
therefore
sues
each
22
Defendant
by
fictitious names.
The
Plaintiff
Is
Informed
andthereupon
alleges
that
each
of the
23
defendants designatedherein
as
DOE
Is
insome way responsible forthe damages claimed
by
the
24Plaintiff herein.ThePlaintiffs (hereinafter referredtoas
"MA
RK
ANON
I
COLE".I
I
OR
 
Case 3
:1
2-cv-00684-
LRH
-
WGC
Document
1·2 Filed
01
/02/13Page4
of
19
1
•PLAINTIFFS
.
)
wlll
ask
leave
of
this court to
~mend
this
complaint
to
Insert
the true
names
and
2 capacities
of
Defendants
DOES
I through
X,
inclusive (hereinafter referred to
as
"NARCONON"
or
3
"DEFENDANTS"),
the
ntheidentitieshavo
been
ascortained,to formulate
appropr
i
ate
allegations
4
and
tojointsuch Defendants
In
this action.5
4.
UponInformationand belief,
at
all times relevant hereto, each
of
the
Defendants
set
6 forth herein
wasthe
principal,agent.employee, employer
or
co-conspi
rator
of
eachother,and
at
7
all relevant times
were
actingwithin the course
and
scope
of
such relationship.
85.
At
all
times
mentioned herein, Defendants' business
address
is Narconon Nevada, Post9
Office
Box
970, Caliente, Nevada89008.
10
6.
Atall times mentioned herein, Narconon
was
doing business
on
the
premis
es
In
Ll
ncolr
11
County, Nevada,
at
the
Rainbow Canyon Retreat,
17095
S.
Route
317,
Caliente,Nevada
89008.
~
I
7.OnMar
ch
8, 2012, Mark
and
Nicole's 15-year·oldson,LI
___
Jl
moved Into the
~·!
~ial
12
~
h~
13 facUlty
at
the Rainbow Canyon Retreat locatedIn LincolnCounty,Nevada,
at
17095
S.
Route 317,
3~1
,
~
a
HCaliente,Nevada.
15
8.
On
March22, 2012,Mark
and
Nicole paidttle
lr
lastpayment
of
$13,500 to Narconon,
16
maldnga total of$39,000
that
they paid
to
Nar·conon
forLI
__
Jts
t
reatme
nt.
17
9.Prior to March8,2012,
Ma
rk
and
Nicole had numerous conversations with
18
AdministrativeStaff
at
the
Rainbow Cnnyon Retreat. During those discussions.they
were
assure
19
that
personalized
therapy
,drug education, constructive
group
therapy,and accesstomedical
sta
2024
hours
per
day were
some
of the
ex
ceptionalbenefitsoffered
by
Narconon
at
the
Rainbow
21
CanyonRetreat. Mark
and
Nicole
were
consoled bypromisesby
the
Narcononadmitting
staff
2.2
tllatLI
----'
1
ould
be
safe, happy, and secure
at
the
Rainbow CanyonR
etreat
duMng his2 3 rehabllillltlon.
24
2
 
Case 3
:1
2-cv-00684-
LRH
-
WGC
Document
1·2 Filed
01
/02/13Page5 of19
1
10.
On
an
ongoing basis
from
thedateJ
_
_-'
1esidedat the
Rainbow
Canyon
Retreat.h
2
was subjected
to
bullying
andharrassmentby older residen
ts.
3 11.
Thr.e
d'lys
followin1
his
admln
lon
to
the
Rainbow
Canyon
Retreat. on or about
4
March
11.
2012,
LI
_
_,lwas
permanently branded.
While
he
was sleeping, several other
S
residents branded
his
ann with
a
piecr.
of
metal
from
a
bedspri
ng.
When
L _
_,
I
wakened
In
6
pain.
they
forcibly
held
him
down
until
he
sustained
a
dlsftgurfng wound.
7
12.
OnApril7, 2012,
._
 _
__,
I
was
on
the
porch
smoking a cigarette.A 27-year-old
male
8
approached
._I
_
__,
land
slapped
the
ctgarettt
out ofL _
_,
rs
mouth.
A
lightensued, and
9
11
__
_,
1
ustained
a
laceratlon on his neck anda
bloody
Up.
Mark
and
Nicole
were never
notified
10o
fLI
--'rslnfurtes.
11
13.
Three
weeks
;lfterL.
 _
_,
I
ntered the
Rainbow
Canyon
program,
two
of
his
12
teenagedroommates graduated.
Another
27-year-old
male
was placed ln
._l
_
__,
rs
oom.
Due
13
the
age
d
ifference,._!
_
__,
Iwasvery uncomfortable with this arrangement
._I
_
__,I
called
Mark
14'
and
Nicole
and
asked them to contact
the
facility
and
have
the27-
yea
r·old removed
from
the15
room.Mark
and
Nico
le
did
so,
pointing out
to
Narconon
staffthatthey had been assuredthat 16only
ma
le teenagers would
be
rooming
w1th
L.I
--'~
Mark
spoke
with
Patty,
the
Ra
in
bow
17ca
ny
on representative.Pattyagreed
to
remove
the
27-yea
r·old
male
from._l
_
__,rs
room;
18
however,
this was never
done. The
27·year-o
ld
only left after
he
gr
aduated
fro
mthe
program.
19
14.
Approximately
one
week
after
L.
 _
__,r
s
dmission to the
RainbowCanyon
Retreat,20
ll
r---,1
was
started on a
•s
aunaprogram•.!jwas
forced
to
endure saunas
for
five
hours a
21
a time wi
th only
short breaks.
L.l
_
_,I
endured twenty four
(24)
consecutive
days
of saunas that
22
lasted threehoursand
forty
minutes
apiece.
Ll
_ _,!sustai
ned
dally
sca
l
ding
from
the
heat.
23
24
3

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