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1FIRST AMENDED COMPLAINT12345678910111213141516171819202122232425262728
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.))))))))))))))))
CASE NO. BC405834PLAINTIFF’S FIRST AMENDEDCOMPLAINT FOR:1)
 
UNFAIR PRACTICES UNDER B&P §17200 ET. SEQ2)
 
DISCRIMINATION & INVASIONOF PRIVACY3)
 
HUMAN TRAFFICKING (CIVILCODE 52.5, PENAL CODE236.1) ASSIGNED TO THE HONORABLE MARY ANN MURPHY, DEPT. 25INTRODUCTION
1)
 
This case challenges Scientology’s long-standingpractice of evading laws and depriving workers of basic humanrights. In particular, Plaintiff complains that she worked longhard hours for illegal wages, was forced to have abortions tokeep her job and was subjected to violations of personal rightsand liberties by Defendants for purposes of obtaining forcedlabor.
 
 
2FIRST AMENDED COMPLAINT12345678910111213141516171819202122232425262728
2)
 
Plaintiff’s case has a solid legal foundation. It issupported by statutory law and decisions of the U.S. SupremeCourt, the California Supreme Court and the Ninth Circuit Courtof Appeals. Defendants’ case appears to be based on the premisethat its status as a tax-exempt entity provides an impermeableshield against claims. In particular, Defendants CSI and RTC,which are part of the Scientology enterprise (“Scientology”),typically claim First Amendment or waiver type defenses toongoing violations of state and federal law. These purporteddefenses to otherwise indisputably illegal conduct will notwithstand scrutiny and analysis. The law is well settled thatDefendants are subject to labor laws and other neutral laws ofgeneral applicability. Further, the rights in question cannot bewaived. Fundamental rights and the protection of the labor lawscannot be lost with the stroke of a pen or word processor.(Authorities are referenced and cited below.)3)
 
The goals of this case include stopping the practice ofordering female employees to have abortions, stopping thepractice of oppressive child labor and clearing the path forworkers of Scientology organizations to obtain the compensationdue them under state and federal labor laws. Plaintiff seekspayment for her work at minimum wage, overtime pay, a permanentinjunction against forced abortions and other remedies authorizedby law.4)
 
Defendant Church of Scientology International (CSI)represents itself to be the “Mother Church” of Scientology. CSIhas its principal office and apparent headquarters in Los
 
 
3FIRST AMENDED COMPLAINT12345678910111213141516171819202122232425262728
Angeles, California. The County of Los Angeles is an appropriatevenue for this action.5)
 
Religious Technology Center (hereinafter “RTC”)purports to be a California non-profit corporation. RTC’s rolein the corporate shell game of the Scientology enterprise is topolice access and use of L. Ron Hubbard’s works. RTC supposedlyprotects copyrighted material and trademarks. RTC charges feesfor protection of intellectual property rights and is thereforeinherently a commercial enterprise.6)
 
Plaintiff Claire Headley worked for Defendants at belowminimum wage compensation from 1991 to 2005. Generally,Plaintiff’s work duties were clerical and secular in nature.Plaintiff is currently a resident of Los Angeles, California.7)
 
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.8)
 
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 1 - 10as authorized by California law. Doe Defendants 11 - 20 arethose potential Defendants who may participate in wrongful
of 00

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braingarbage

this is so exciting!!! van sickle take good care and keep up the good fight!

reply11 / 20 / 2009
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