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Ryan A. Hamilton
NEVADA BAR NO. 11587
HAMILTON LAW
5125 S. Durango Dr., Ste. C
Las Vegas, NV 89113
(702) 818-1818
(702) 974-1139 (fax)
ryan@hamiltonlawlasvegas.com

Attorney for the plaintiffs


UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEVADA

CHARIS YATES, a Washington Citizen;
BERET PUGH, a Washington Citizen; and
DEAN PUGH, a Washington Citizen,

Plaintiffs,

vs.

NARCONON FRESH START d/b/a RAINBOW
CANYON RETREAT, a California Corporation;
ASSOCIATION FOR BETTER LIVING AND
EDUCATION INTERNATIONAL;
NARCONON INTERNATIONAL; and DOES
1-100, ROE Corporations I X, inclusive,

Defendants.



Case No.



COMPLAINT AND JURY DEMAND


Plaintiffs Charis Yates, Beret Pugh, and Dean Pugh (Plaintiffs), allege, by and through
their attorney, Ryan Hamilton of Hamilton Law, LLC, the following:
I.
PARTIES
1. Plaintiffs are, and at all relevant times to this Complaint were, citizens of Washington.
2. Defendant Narconon Fresh Start is, and at all times relevant to this Complaint was, a
corporation incorporated under the laws of, and with its principal place of business in, the State of
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California. Fresh Start has been at all relevant times transacting business in Caliente, Lincoln
County, Nevada. Fresh Start may be served with process through its registered agent, Mark
Kirwin, 4480 Market St., Ste. 804, Ventura, CA 93003.
3. Defendant Narconon International (NI) is a California corporation with its headquarters
in Los Angeles, California.
4. NI is the parent/licensor of Defendant Narconon Fresh Start. NI exercises control over the
time, manner, and method of Fresh Starts operations.
5. NI was doing business in the State of Nevada by and through its agent and
subsidiary/licensee Defendant Narconon Fresh Start. NI may be served with process through its
registered agent, Sherman D. Lenske, 6400 Canoga Ave., Suite 315, Woodland Hills, CA 91367.
6. Fresh Start and NI are subsidiaries of the Association for Better Living and Education
(ABLE). ABLE oversees the drug rehabilitation, education, and criminal justice activities of the
Church of Scientology including, but not limited to, Fresh Start and NI.
7. Defendant ABLE is a corporation registered in the State of California with its headquarters
in Los Angeles, California.
8. ABLE controls the time, manner, and method of NIs and Fresh Starts businesses by
actively managing their daily operations, including conducting inspections of Narconon centers
and creating, licensing, and approving their marketing materials.
9. ABLE transacts business in the State of Nevada by and through its agents, Narconon
International and Narconon Fresh Start. ABLE may be served with process through its registered
agent, Sherman D. Lenske, 6400 Canoga Ave., Suite 315, Woodland Hills, CA 91367.
10. Plaintiffs are unaware of the true names and capacities, whether individual, corporate,
associate, or otherwise, of Defendant DOES 1-100, inclusive, and, therefore, sues these
Defendants by fictitious names. Plaintiffs will seek leave of this Court to amend this Complaint
when the identities of these Defendants are ascertained.
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II.
JURISDICTION AND VENUE
11. This Court has subject jurisdiction pursuant to 28 U.S.C. 1332. The amount in
controversy exceeds $75,000.00, and there is complete diversity between the parties.
12. Venue is proper in this Court pursuant to 28 U.S.C. 1391(a) because a substantial portion
of the events and omissions giving rise to this lawsuit occurred in this District, and the Court has
personal jurisdiction over each of the parties as alleged throughout this Complaint.
III.
FACTUAL ALLEGATIONS
13. On or about August 30, 2012, Plaintiffs Charis Yates and Dean Pugh were seeking
substance abuse treatment for their daughter, Plaintiff Beret Pugh.
14. Dean spoke on the telephone with Dan Carmichael, Admissions Director for Fresh Start,
about getting treatment for his daughter, Beret. Dean also spoke with another Fresh Start
salesperson named Ryan.
15. During their conversations, Carmichael and Ryan made numerous material false
representations of fact.
15. First, Carmichael and Ryan falsely represented to Dean that the Fresh Start treatment
program has over a 76% percent success rate.
16. Second, Carmichael and Ryan falsely represented to Dean that at Fresh Start Beret would
receive extensive substance abuse treatment and counseling from qualified counselors.
17. Third, Carmichael and Ryan falsely represented to Dean that the Fresh Starts sauna
program, the New Life Detoxification program, would reduce or eliminate Berets drug cravings
by flushing residual drug toxins stored in her fatty tissue.
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18. Fourth, Carmichael and Ryan falsely represented to Dean that at Fresh Start Beret would
be under the supervision of licensed medical professionals, including licensed physicians and
nurses.
19. Fifth, Carmichael and Ryan falsely represented to Dean that the Fresh Start program was
secular and did not involve the study or practice of any religion.
20. Based on these false representations, Plaintiffs Dean Pugh and Charis Yates decided to
admit their daughter to the Fresh Start program. They paid $33,000 to Fresh Start for treatment for
Beret. The Contract and Invoice for Fresh Starts services are attached hereto as Exhibit A.
21. The Contract describes the founding of the Narconon program as follows: The Narconon
Program was founded in 1966 by William Benitez, where it was first used in the Arizona State
Prison, after being inspired by the practical betterment philosophy of author and humanitarian L.
Ron Hubbard in the book, The Fundamentals of Thought.
22. The full title of the L. Ron Hubbard book referenced in the Contract is Scientology: The
Fundamentals of Thought.
23. In the same paragraph, the Contract provides, The Narconon Program is secular (NON-
RELIGIOUS) in nature and the program does not include in any participation in any religious
studies of any kind.
24. Despite Fresh Starts representation that it is a secular program, Fresh Start had Beret
unwittingly practicing and studying Scientology in place of counseling for substance abuse.
25. Fresh Start uses the Narconon treatment program.
26. The Narconon treatment program consists of eight books written by, or based on the works
of, L. Ron Hubbard, the founder of Scientology.
27. The books in the Narconon treatment program teach Scientology doctrines and concepts.
There is no apparent connection between the material in the Narconon books and treatment for
substance abuse and addiction.
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28. NI and ABLE license the written materials to individual Narconon centers such as Fresh
Start.
29. NI and ABLE monitor and supervise the individual Narconon centers use of the Narconon
books.
30. Individual Narconon centers such as Fresh Start must administer the Narconon program
exactly as it is written or they risk losing their ability to administer the program.
31. Each patient at an individual Narconon center receives the same treatment program no
matter what substance abuse problem the patient has.
32. Fresh Start administered Beret the Narconon treatment program.
33. The Narconon treatment program also has patients undergo a sauna program, what it calls
the New Life Detoxification Program.
34. The sauna program is actually a Scientology ritual known as the Purification Rundown.
35. Under Narconons sauna program, students first exercise vigorously before entering the
sauna each day. On entering the sauna, Fresh Start requires each student to ingest increasing doses
of Niacin and a vitamin bomb.
36. Fresh Start had Beret participate in the New Life Detoxification program. During her
participation, Fresh Start had Beret ingest extreme doses of Niacin well beyond the recommended
daily allowance.
37. There were no licensed medical personnel, such as doctors or nurses, supervising Beret as
she participated in the sauna program.
38. Fresh Start claimed to Plaintiffs that the New Life Detoxification Program has been
scientifically shown to flush out residual drug toxins stored in fatty tissue thereby reducing or
eliminating a persons drug cravings.
39. Not only does the New Life Detoxification fail to live up to these claims about its benefits,
the sauna program is dangerous. By having students ingest extreme doses of Niacin and other
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vitamins while sitting in extreme temperatures for hours, the sauna program unnecessarily exposes
students to serious health risks including severe dehydration.
40. In a prior lawsuit, Dr. Louis A. Casal, an expert retained by Narconon International and
Narconon of Northern Georgia in a wrongful death suit filed against those entities, testified at a
deposition. Relevant portions of Dr. Casals deposition testimony are attached hereto as Exhibit
B. When asked under oath about Narconons sauna program, he testified that there is no scientific
basis for the notion that sweating in a sauna detoxifies a persons body or treats addiction:
Q. Have you looked at the Narconon literature on what Narconon contends the
benefits from the sauna are?
A. [Dr. Casal] Yes, I have.
Q. And the sauna program, what Narconon contends is that in it in fact detoxifies
your body. True?
A. True.
Q. But theres no scientific basis that you can point to to support that contention, is
there, sir?
A. Youre correct.
Q. So when Narconon states that the sauna program detoxifies its students, youre not
aware, as a medical doctor, of any scientific basis for that contention?
A. I agree.
Exhibit B, Deposition of Dr. Louis Casal, 136:21 137:9.
42. Despite their own experts admission that there is no scientific basis for the idea that
patients sweating in the New Life Detoxification Program treats addiction, Defendants continue to
represent to prospective patients, as they did to Plaintiffs, that the New Life Detoxification has
been scientifically and medically proven as effective.
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43. Defendants represented to Plaintiffs that Fresh Start has a success rate of 76% for all
Narconon centers, including Narconon Fresh Start d/b/a Rainbow Canyon Retreat. Defendants
have published no studies or other verifiable evidence to support their claimed success rates.
44. Dr. Casal, the medical expert retained by Narconon International in another lawsuit,
testified at his deposition that he was not convinced Narconons claimed success rate was true:
Q. Okay. What are you relying on well, let me ask you this; do you believe that 76
percent success ratio is accurate?
A. [Dr. Casal]. Mr. Harris, Ill be honest with you, thats a big number.
Q. Yeah, its its a real big number.
A. Its a big number.
Q. And its completely inconsistent
A. I I hope its true, but, I mean, I would need some convincing.

Q. Okay. Do you have any idea where Narconon is getting the numbers that its using?
A. You know, in the interest of time I just didnt have enough time to delve deeper
into those studies, Mr. Harris. And I I would be happy to, but, no, I dont have a clear
understanding of where that 70 70-something number came from, no, sir.
Exhibit B, Deposition of Dr. Louis Casal, 124:21 125:5; 126:1 7.
45. Defendants are well aware that there is no support for Narconons claimed success rate, but
nonetheless advertised a 76% success rate to Plaintiffs.
46. Narconon documents indicate that the Narconon program is used to recruit patients into the
Church of Scientology. For example, a Narconon document titled the Narconon Technical Line-
Up provides a flow chart of a patients experience into and through the Narconon program. The
document shows that when a patient finishes the Narconon program, the patient is to be route[d]
to the nearest Org for further services if the individual so desires. Org is Scientology jargon for
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an individual church providing services for the Church of Scientology. A copy of the Narconon
Technical Line-Up is attached hereto as Exhibit C.
47. Defendants consider the Narconon treatment program to be the Bridge to the Bridge.
That is, Narconon considers its program to be an initial step into getting on Scientologys Bridge
to Total Freedom, the key spiritual journey that practitioners of the Scientology religion
undertake. See, e.g., Narconon News, 1974, Volume 6, Issue 3: Narconon Is The Bridge to The
Bridge, attached hereto as Exhibit D.
48. Despite Defendants representations that Beret would receive extensive counseling at Fresh
Start, at no point did staff ever speak to her about the specifics of her drug use and its causes.
49. Beret did not receive any of the counseling or substance abuse treatment at Fresh Start that
Plaintiffs had been promised.
50. In contrast to Defendants representations to Dean that Beret would be receiving treatment
from duly qualified and licensed professionals, the staff at Fresh Start consisted almost entirely of
former graduates of the Narconon program. These personnel were not licensed counselors,
therapists, or addiction specialists.
51. Beret left Fresh Start early because she was not receiving any actual addiction treatment.
She left Fresh Start much worse than when she entered and relapsed almost immediately. Plaintiffs
have incurred expenses to get Beret the treatment Defendants promised to provide. Further, Beret
has had to get help for the injuries Defendants treatment caused her.
ALTER EGO LIABILITY
52. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further alleges as follows:
53. Defendants Narconon Fresh Start and NI have all appearances of being a corporate sham
illusion and mere instrumentalities of Defendant ABLE.
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54. ABLE heavily influences Narconon Fresh Start and NI and governs and controls nearly
every aspect of their business activities.
55. There is such unity of interest and ownership among Narconon Fresh Start, NI, and ABLE
that they are inseparable from one another.
56. The separate corporate existences of Narconon Fresh Start, NI, and ABLE is a design or
scheme to perpetrate a fraud. The separate corporate existences of Narconon Fresh Start, NI, and
ABLE is a scheme to fraudulently induce patients to enroll in one of their treatment facilities and
pay substantial funds. Further, Defendants perpetrate this scheme to recruit for and promote the
Scientology religion.
57. It is interests of justice to disregard the corporate shield and treat Defendants Narconon
Fresh Start, NI, and ABLE as identical. Accordingly, each cause of action listed below is made
against all Defendants.
FIRST CLAIM FOR RELIEF
BREACH OF CONTRACT
58. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation
set forth in the preceding paragraphs and further allege as follows:
59. Plaintiffs and Defendants were bound by a Contract whereby Defendant agreed, in
exchange for consideration, to provide secular, residential drug and alcohol treatment to Beret
Pugh.
60. Defendants breached this contract by, inter alia: (i) failing to provide services constituting
drug and alcohol treatment; and (ii) providing Scientology in lieu of drug and alcohol treatment.
61. Defendants breaches have caused Plaintiffs to suffer damages in excess of $75,000.00.
SECOND CLAIM FOR RELIEF
FRAUD
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62. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
63. The following is a non-exhaustive list of false representations Defendants knowingly
made to Plaintiffs: (i) that the Narconon Fresh Start program has a 76% success rate; (ii) that the
Narconon program is secular and does not involve the study or practice of any religion; (iii) that
Beret would receive counseling related to substance abuse at Fresh Start; (iv) that Fresh Starts
sauna program, i.e, the Purification Rundown, is safe and has been scientifically proven as
effective to reduce or eliminate drug cravings; and (v) that Beret would be under the care of
licensed medical professionals, such as doctors or nurses, at Fresh Start.
64. Acting on behalf of Defendants, Dan Carmichael and Ryan of Fresh Start, made these
statements to Dean Pugh on or about August 30, 2012, to induce Dean and Charis to send their
daughter to Fresh Start.
65. Had Plaintiffs known that any of the above representations Defendants made were false,
they would not have sent Beret to Fresh Start, nor paid Fresh Start a substantial sum of money.
66. As a proximate result of Defendants fraudulent conduct, Plaintiffs have suffered damages
in excess of $75,000.00.
THIRD CLAIM FOR RELIEF
NEGLIGENCE
67. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
68. Defendants owed Plaintiffs a duty to render substance abuse treatment to Beret Pugh in a
manner that did not subject her to an unreasonable risk of harm. Defendants further had a duty of
care to render reasonably safe and effective treatment to Beret Pugh.
69. Defendants breached these duties by: (i) instructing Beret to sit in a sauna for 5 hours per
day while ingesting extreme dosages of Niacin; (ii) failing to staff the Fresh Start treatment
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facility, and particularly the sauna, with any qualified medical personnel; (iii) failing to provide
duly qualified counselors to administer treatment; and (iv) providing Scientology in lieu of
substance abuse treatment.
70. As a proximate result of Defendants breaches of the above duties, Plaintiff Beret Pugh has
suffered injuries in excess of $75,000.00.
FOURTH CLAIM FOR RELIEF
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
71. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
72. Defendants engaged in extreme and outrageous conduct with the intention of causing, or
with reckless disregard of the probability of causing Plaintiffs severe or extreme emotional
distress. Defendants extreme and outrageous conduct consisted of, inter alia: providing Beret
Pugh Scientology in lieu of drug treatment or substance abuse counseling; preying on Plaintiffs
vulnerabilities and attempting to recruit Plaintiff Beret Pugh into Scientology under the guise of
providing drug treatment.
73. As a proximate result of Defendants extreme and outrageous conduct, Plaintiff Beret Pugh
has suffered severe and extreme emotional distress beyond what any person in a civilized society
should be expected to endure.
FIFTH CLAIM FOR RELIEF
NEGLIGENT MISREPRESENTATION
74. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
75. Defendants made the following false representation of fact to Plaintiffs: (i) that the
Narconon Fresh Start program has a 76% success rate; (ii) that the Narconon program is secular
and does not involve the study or practice of any religion; (iii) that Beret would receive counseling
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related to substance abuse at Fresh Start; (iv) that Fresh Starts sauna program, i.e, the Purification
Rundown, is safe and has been scientifically proven as effective to reduce or eliminate drug
cravings; and (v) and that Beret would be under the care of licensed medical professionals, such as
doctors or nurses, at Fresh Start.
76. Acting on behalf of Defendants, Dan Carmichael and Ryan of Fresh Start, made these
statements to Dean Pugh on or about August 30, 2012, to induce Plaintiffs Dean Pugh and Charis
Yates to send their daughter to Fresh Start.
77. Defendants made these statements to Plaintiffs in the course of Fresh Starts business.
These statements were for Plaintiffs guidance in their transaction with Fresh Start. Plaintiffs
relied on these false statements of fact resulting in substantial pecuniary loss and other injuries to
Plaintiffs.
78. Defendants made these statements without exercising reasonable care.
SIXTH CLAIM FOR RELIEF
NEGLIGENCE PER SE
79. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
80. Defendants performed medical procedures on Plaintiff Beret Pugh for which a medical
license was required under NRS 630.160. Such procedures included non-physicians instructing
Beret Pugh to ingest extreme doses of Niacin while undergoing Fresh Starts sauna program.
81. Plaintiff Beret Pugh is in the class of persons the license requirement under NRS 630.160
is intended to protect and the injury she sustained is of the type against which the statute is
intended to protect.
82. As a proximate result, Plaintiff Beret Pugh sustained injuries.
///
///
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SEVENTH CLAIM FOR RELIEF
CIVIL RICO FOR MAIL AND WIRE FRAUD, 18 U.S.C. 1964(c)
83. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
84. Plaintiffs have been injured by Defendants conduct of an enterprise through a pattern of
racketeering activity.
85. Defendants have engaged in a scheme to defraud Plaintiffs and countless others. In
furtherance of that scheme, Defendants have committed countless acts of mail fraud and wire
fraud under 18 U.S.C. 1962 within the preceding ten years.
86. Defendants perpetrate this scheme as follows: When prospective patients or their loved
ones are referred to Narconon facility, they then speak to an intake specialist. The intake specialist
following a script makes claims that Narconon knows to be false and without scientific support
such as the claims that Dan Carmichael and Ryan made to Plaintiffs in this case on or about
August 30, 2012. These false claims include: (i) that Narconon has a more than 76% success rate;
(ii) that Narconons sauna program reduces or eliminates drug cravings by eliminating toxins from
an addicts fatty tissue; (iii) that patients at Narconon will receive extensive drug counseling; (iv)
that the Narconon treatment program does not involve the study or practice of any religion; and (v)
that patients at the Narconon facility will be under the supervision of licensed physicians and other
medical personnel.
87. Defendants also mail prospective clients such as Plaintiffs pamphlets making these same
false claims to induce them to enter into the program. Defendants refer prospective patients to its
website where these false claims are also made. NI and ABLE approve Narconon Fresh Starts
marketing materials and scripts that contain these false claims.
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88. As was the case here, Defendants recruit prospective clients from different states in which
the facility is located. For that reason, Defendants use of the phones, wires, mail, and internet is
integral to their fraudulent scheme.
89. When patients such as Beret Pugh enter the Narconon treatment program, instead of
receiving the extensive counseling and substance abuse treatment they and their families were
promised, Narconon provides only instruction in Scientology and dangerous Scientology rituals
such as the sauna program. In addition, Defendants use their treatment program as a recruiting tool
for the Church of Scientology, as evidenced by Defendants own documents, attached hereto as
Exhibits C and D.
90. While a patient is undergoing the program, Defendants prepare the patient to become a
Narconon staff member following the patients completion of the program. In doing so, the patient
becomes a counselor for the next wave of incoming patients. This scheme allows Defendants to
pay a patient-turned-counselor low wages and Defendants are spared the relatively higher cost of
paying duly qualified addiction counselors.
91. As a result of Defendants racketeering activity, Plaintiffs have suffered pecuniary
damages and other injuries.
EIGHTH CLAIM FOR RELIEF
BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
92. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
93. The contract Plaintiffs Dean Pugh and Charis Yates entered into with Defendants for
Defendants to provide treatment to Beret contained an implied covenant of good faith and fair
dealing.
94. Defendants acted unfaithfully to the purpose of the contract and Plaintiffs justified
expectations by, inter alia: (1) having Beret unwittingly study and practice Scientology in lieu of
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engaging in drug treatment; and (2) attempting to have Beret surrender her legal rights in
exchange for services for which Plaintiffs had already provided consideration; and (3) persuading
Dean and Charis to send Beret to Fresh Start with promises that Narconons sauna program would
reduce or eliminate his drug cravings by flushing toxins and then asking Beret at Narconon to sign
an acknowledgement that the sauna program is not a medical program and that it provides no
physical gains.
95. As a consequence of Defendants breaches, Plaintiffs have suffered damages.
NINTH CAUSE OF ACTION
CIVIL CONSPIRACY
96. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
97. Defendants intended to act in concert to accomplish the unlawful objectives of
indoctrinating and recruiting Plaintiff Beret Pugh into Scientology under the guise of providing
her with drug treatment.
98. Defendants further acted in concert to have non-physicians perform medical procedures on
Plaintiff Beret Pugh for which a medical license was required under NRS 630.160.
99. As a proximate result of Defendants intentional actions in concert to accomplish unlawful
objectives to harm Plaintiff Beret Pugh, she has been harmed.
TENTH CAUSE OF ACTION
FRAUD CLAIMS PURSUANT TO NRS 41.600
100. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
101. By reason of Defendants actions complained of herein, Plaintiffs are victims of consumer
fraud.
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102. Defendants have engaged in numerous deceptive trade practices as defined in NRS
598.0915 to 598.0925, inclusive. The following is a non-exhaustive list of the deceptive trade
practices Defendants have engaged in with respect to Plaintiffs: (i) advertising substance abuse
treatment with the intent not to sell them as advertised by providing Scientology instead; (ii)
knowingly making false representations about the Narconon treatment programs success rate, the
personnel delivering the treatment program, and the benefits of the sauna program; (iii) using bait
and switch advertising whereby Defendants advertise extensive substance abuse counseling and
treatment and then deliver a treatment program wherein the patient receives only Scientology
instruction and dangerous Scientology rituals; (iv) failing to disclose material facts to Plaintiffs
about the services Defendants were selling including, but not limited to, the fact that Defendants
treatment program consisted of Scientology doctrines and practices and the staff at Fresh Start
consisted of graduates of the Narconon treatment program without any other qualification; and (v)
making assertions of scientific, clinical, or quantifiable fact without having appropriate evidence
such as Defendants assertions of its 76% success rate for its treatment program and Defendants
claims that the New Life Detoxification Program can reduce or eliminate drug cravings.
103. Plaintiffs have been the victims of Defendants deceptive trade practices listed above and,
as a result, have suffered substantial pecuniary damages and other injuries.
104. Defendants deceptive trade practices are likely to continue absent court intervention.
105. Plaintiffs are entitled to all available relief under NRS 41.600 including Plaintiffs
attorneys fees and costs of this action, an award for their damages, and an injunction restraining
Defendants from further engaging in the deceptive trade practices complained of herein.
DEMAND FOR JURY TRIAL
Plaintiffs demand a jury trial on all issues triable.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs prays for the following relief:
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A. Judgment in favor of Plaintiffs and against Defendants for damages in such amounts as
may be proven at trial;
B. Compensation for special, general, and treble damages, as well for loss of parental
consortium;
C. Reasonable attorneys fees and costs of suit;
D. Interest at the statutory rate;
E. Punitive or exemplary damages against Defendant;
F. Injunctive relief restraining Defendants from further engaging in deceptive trade practices;
and
G. All further relief, both legal and equitable, that the Court deems just and proper.

DATED this May 27, 2014.

Respectfully submitted,

By:_/s/Ryan A.Hamilton_
RYAN A. HAMILTON, ESQ.
NEVADA BAR NO. 11587
HAMILTON LAW
5125 S. Durango Dr., Ste. C
Las Vegas, NV 89113
(702) 818-1818
(702) 974-1139
ryan@hamiltonlawlasvegas.com

Attorney for Plaintiffs

Case 2:14-cv-00837 Document 1 Filed 05/27/14 Page 17 of 17