1 Complaint for Damages
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D
AVID
E.
M
ILLER
(CA
B
AR
S
AEED
&
L
ITTLE
,
LLP
1433 N. Meridian St., Ste 202 Indianapolis, IN 46202 Office: (317) 721-9214 Facsimile: (888) 422-3151
Attorney for Plaintiffs
IN THE UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
SAMANTHA NORD-SHAFER, a Delaware Citizen; & REBECCA KENNEDY, a New York Citizen; Plaintiff, vs. ASSOCIATION OF BETTER LIVING AND EDUCATION INTERNATIONAL, a California Corporation; NARCONON INTERNATIONAL, a California Corporation; NARCONON FREEDOM CENTER d/b/a NARCONON FREEDOM TREATMENT CENTER, a Michigan Corporation; & DOES 1-100; ROE CORPORATIONS I-X, inclusive, Defendants. Case No.:
REQUEST FOR INJUNCTIVE RELIEF, COMPLAINT FOR DAMAGES, AND JURY TRIAL DEMAND Count 1: Breach of Contract Count 2: Negligence Count 3: Fraud Count 4: Premise Liability Count 5: Request for Injunctive Relief I.
I
NTRODUCTION
1.
Plaintiff Samantha Nord-Shafer
(hereinafter “Plaintiff”)
and Plaintiff
Rebecca Kennedy (hereinafter “Ms. Kennedy”) (known collectively as
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“Plaintiffs”)
alleges on information and belief against Association of Better Living and Education International, Narconon International, Narconon Freedom Center d/b/a Narconon Freedom Treatment Center, and Does 1-100, ROE Corporations I-X, inclusive, the following:
II.
P
ARTIES
2.
Plaintiff Samantha Nord-Shafer is currently a resident of Dover, Delaware and is twenty four years old. Ms. Nord-Shafer attended the Albion, Michigan facility to seek treatment for her drug addiction.
3.
Plaintiff Rebecca Kennedy is the mother of Samantha Nord-Shafer and is a resident of Windsor, NY. Ms. Kennedy discovered the Narconon facility in Albion, Michigan and paid for Ms. Nord-Shafer to attend there based on information she was provided by Defendants. 4.
Defendant Narconon International (hereinafter
“NI”) is a California
corporation with its principal place of business is Los Angeles, California. Narconon International may be served with process through its registered agent, Sherman D. Lenske, 6400 Canoga Avenue, Suite 315, Woodland Hills, CA 91367. 5.
NI is the parent/licensor of Narconon Freedom Center d/b/a Narconon Freedom Treatment Center (hereinafter
“
NFC
”
). NI exercises control over the time, manner, and method in which
the operations and administration of NFC’s
facility are run.
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6.
NI was doing business in the State of California by and through its agent and subsidiary/licensee NFC. NI may be served with process through its registered agent, Sherman D. Lenske, 6400 Canoga Ave., Suite 315, Woodland Hills, CA 91367.
7.
NFC and NI are subsidiaries of the Association for Better Living and Education (hereinafter
“ABLE”). ABLE oversees the drug rehabilitation,
education, and criminal justice activities of the Church of Scientology including, but not limited to, NFC and NI.
8.
Defendant ABLE is a corporation registered in the State of California with its headquarters in Los Angeles, California.
9.
ABLE controls the time, manner, and method of NI’s and NFC’s
businesses by actively managing their daily operations, including conducting inspections of Narconon centers and creating, licensing, and approving their marketing materials.
10.
ABLE transacts business in the State of California by and through its agents, NI and NFC. ABLE may be served with process through its registered agent, Sherman D. Lenske, 6400 Canoga Ave., Suite 315, Woodland Hills, CA 91367.
11.
Defendant Narconon Freedom Center d/b/a Narconon Freedom Treatment Center, is, and at all times has relating to Plaintiff
s’
injuries was, a
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