Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more ➡
Download
Standard view
Full view
of .
Add note
Save to My Library
Sync to mobile
Look up keyword
Like this
3Activity
×
0 of .
Results for:
No results containing your search query
P. 1
SAC - Revised

SAC - Revised

Ratings:

4.75

(4)
|Views: 1,737|Likes:
Published by Larry Brennan
the second amended complaint in the case of Laura DeCrescenzo vs.Church of Scientology International, RTC, et al
the second amended complaint in the case of Laura DeCrescenzo vs.Church of Scientology International, RTC, et al

More info:

categoriesBusiness/Law, Finance
Published by: Larry Brennan on Feb 04, 2010
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See More
See less

07/12/2013

pdf

text

original

 
12345678910111213141516171819202122232425262728
F:\WP\Cases\9527\PLEADDOC\COMPLAIN\SAC - Revised.wpd
BARRY VAN SICKLE, ESQ., SBN 986451079 SUNRISE AVENUE, SUITE B-315ROSEVILLE, CA 95661TELEPHONE: (916) 549-8784EMAIL:barryvansickle@comcast.netMETZGER LAW GROUPA PROFESSIONAL LAW CORPORATIONRAPHAEL METZGER, ESQ., SBN 116020401 E. OCEAN BLVD., SUITE 800LONG BEACH, CA 90802-4966TELEPHONE: (562) 437-4499TELECOPIER: (562) 436-1561Attorneys for PlaintiffLaura Ann DeCrescenzoSUPERIOR COURT OF THE STATE OF CALIFORNIAFOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICTLAURA ANN DeCRESCENZO, akaLAURA A. DIECKMAN,Plaintiffs,vs.CHURCH OF SCIENTOLOGYINTERNATIONAL, a corporateentity, RELIGIOUS TECHNOLOGYCENTER, previously sued hereinas Doe No. 1, a Californiacorporation, AND DOES 2 - 20,Defendants._______________________________))))))))))))))))CASE NO. BC411018
Assigned to the HonorableRonald M. Sohigian, Dept. 41
SECOND AMENDED COMPLAINT ASSERTING CAUSES OF ACTION FOR:(1)FORCED ABORTION IN VIOLATION OF ARTICLE I,SECTION 1 OF THECALIFORNIA CONSTITUTION;(2) FORCED ABORTION IN VIOLATION OF COMMON LAW;(3)DEPRIVATION OF LIBERTY IN VIOLATION OF ARTICLE I,SECTION 1 OF THECALIFORNIA CONSTITUTION;(4) FALSE IMPRISONMENT;(5) INTENTIONAL INFLICTION OFEMOTIONAL DISTRESS;(6)VIOLATION OF LABOR CODE§§ 970 AND 1194; AND(7)VIOLATION OF BUSINESS &PROFESSIONS CODE § 17200DEMAND FOR JURY TRIAL [MADEPURSUANT TO CALIFORNIA CODE OCIVIL PROCEDURE §§ 600 ET SEQ. AND PURSUANT TO RULE 38 OF THEFEDERAL RULES OF CIVILPROCEDURE SHOULD THIS CASE EVER BE REMOVED TO FEDERAL COURT]
SECOND AMENDED COMPLAINT
 
12345678910111213141516171819202122232425262728
F:\WP\Cases\9527\PLEADDOC\COMPLAIN\SAC - Revised.wpd
Plaintiff, Laura Ann DeCrescenzo, hereby alleges:THE PARTIES1. At all material times hereto, Plaintiff, Laura AnnDeCrescenzo, resided and worked in the State of California.2. Plaintiff is informed and believes and thereon allegesthat Defendant, Church of Scientology International (“CSI”), is aCalifornia corporation, which at all material times hereto, was doingbusiness in the County of Los Angeles, State of California.3. Plaintiff is informed and believes and thereon allegesthat Defendant, Religious Technology Center (“RTC”), previously suedherein as Doe No. 1, is a California corporation, which at allmaterial times hereto, was doing business in the County of LosAngeles, State of California.4. The true names and capacities of Defendants Does 2through 20 are unknown to Plaintiff, who therefore sues saiddefendants by such fictitious names. Plaintiff will amend thiscomplaint to state the true names and capacities of said fictitiousdefendants when they have been ascertained. Plaintiff is informedand believes and thereon alleges that Defendants Does 2 through 20are in some manner responsible for the occurrences herein alleged,and that Plaintiff’s damages as herein alleged were proximatelycaused by their conduct.////////
2
SECOND AMENDED COMPLAINT
 
12345678910111213141516171819202122232425262728
F:\WP\Cases\9527\PLEADDOC\COMPLAIN\SAC - Revised.wpd
GENERAL ALLEGATIONS5.From approximately 1991 to 2004, Plaintiff wasemployed by Defendant, CSI. During this time, Plaintiff worked andlived at Defendant, CSI’s facilities located in Los Angeles,California. Plaintiff started working for Defendant, CSI, at agetwelve and continued working for Defendant, CSI, until age twenty-five. As alleged in detail below, during Plaintiff’s employment,Defendant, CSI, deprived Plaintiff of her rights to privacy andliberty, intentionally caused Plaintiff severe emotional distress,and failed to pay Plaintiff minimum wage or post required wageorders.6.Plaintiff also worked for Defendant, RTC. Defendant,RTC, was responsible for and directly oversaw a number of thepolicies and conditions of Plaintiff’s employment. Moreover, one ormore top RTC executives were actively involved in drafting and usingbogus forms, releases, and purported contracts to scare andintimidate its employees, including Plaintiff, even though Defendant,RTC, knew that said forms and waivers were unenforceable and contraryto law.////////////////
3
SECOND AMENDED COMPLAINT

Activity (3)

You've already reviewed this. Edit your review.
1 hundred reads
1 thousand reads
SLAVEFATHER liked this

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->