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1 Tracy R.

Reinmiller (SBN 189029) REINMILLER LAW FIRM

2 500 N. State College Blvd., Ste. 1100

t\\ Orange, CA 92868

It \'VI Telephone: (714) 919-4350 'f 4" ,,,£,acsimile: (714) 919.4390

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FILED

SUPERIOR COURT OF CALIF RNrA COUNTY OF ORANGE CENTRAL JUSTICE: CENT

AUG 042009

Attorneys for Plaintiffs, MICHAEL JACOBS and JEFF JACOBS

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ORANGE - CENTRAL JUSTICE CENTER

MICHAEL JACOBS, an individual, JEFF JACOBS, an individual,

Plaintiffs,

vs.

NARCONON SOUTHERN CALIFORNIA, a California Corporation, and DOES 1 through 50, inclusive,

Defendants.

23 24 25 26 27 28

30-2009 00289722

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22 COME NOW, Plaintiffs, MICHAEL JACOBS and JEFF JACOBS, and allege as follows:

Case No.:

COMPLAINT FOR:

1. BREACH OF CONTRACT;

2. UNJUST ENRICHMENT;

3. FRAUD - INTENTIONAL CONCEALMENT;

4. FRAUD - NEGLIGENT MISREPRESENTATION;

5. CONVERSION; AND

6. UNFAIR COMPETITION (BUS & PROF CODE § 17200)

JUDGE PETER J. POlOS DEPT. C27

1.

JURISDICTION AND VENUE

At all times herein mentioned, Plaintiff, MICHAEL JACOBS (hereinafter

"MICHAEL") is, and was, an individual, residing in the County of Orange, State of California.

2. At all times herein mentioned, Plaintiff, JEFF JACOBS (hereinafter "JEFF") is,

and was, an individual, residing in the County of Orange, State of California.

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COMPLAINT

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28 3. At all times herein mentioned, Defendant, NARCONON SOUTHERN

CALIFORNIA (hereinafter "NARCONON") is, and was, a California corporation authorized to and doing business in California, with its principal office located in the County of Orange, State of California. Further Defendant NARCONON solicits business from customers throughout the state, including customers in the County of Orange, State of California.

4. Defendants DOES I through 50, inclusive, whether individual, corporate,

associate, or otherwise are unknown to Plaintiff, who therefore sues these Defendants herein under fictitious names. When their true names and capacities are ascertained, Plaintiff will amend this complaint by inserting their true names and capacities herein.

5. At all times relevant to this action, each Defendant, including those fictitiously

named, was the agent, servant, employee, partner, joint venturer, or surety of the other Defendants and was acting within the scope of said agency, employment, partnership, venture, or suretyship, with the knowledge and consent or ratification of each of the other Defendants in doing the things alleged herein.

6. Venue is proper as Defendant business is located in the County of Orange.

GENERAL ALLEGATIONS

7. On or about April 18,2008, Plaintiff, MICHAEL admitted his adult son, JEFF to

Defendant, NARCONON'S Newport Beach facility for the primary purposes of receiving detoxification from substance abuse and to receive medically supervised substance abuse recovery treatment, including, but not limited to, group and/or individual psychological counseling or treatment, and medical supervision by a qualified physician.

8. Prior to admitting JEFF to NARCONON, JEFF, MICHAEL and JEFF'S mother,

Linda Jacobs, spoke on the telephone with Dan Carmichael, Intake Counselor at NARCONON and self-proclaimed NARCONON success story. Mr. Carmichael told them that JEFF would be "well taken care of," "in good hands," and that NARCONON boasted a high success rate for persons with substance abuse problems, like JEFF.

9. Linda Jacobs was further told by Mr. Carmichael that the detoxification would be

medically supervised, and that JEFF would have access to a steam room and weight room to

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COMPLAINT

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28 "help him get through the detox." These representations are also found on the website for Defendant NARCONON. NARCONON'S web page further claims that the rehab center

provides a safe environment and caring staff.

10. Based upon the oral representations by NARCONON, and its agents, employees

or representatives, including Mr. Carmichael, JEFF agreed to enter the substance abuse program

at NARCONON'S Newport Beach facility on April 18, 2008 and MICHAEL agreed to pay the

fee for the substance abuse recovery program.

11. At all times mentioned herein, JEFF, MICHAEL and Linda Jacobs were informed

and believed that the substance abuse treatment program consisted of a 3~day medically supervised detoxification, to be followed by a minimum thirty (30) day in-patient medically supervised treatment program.

12. Upon arrival at the facility, MICHAEL was informed that the cost for the program

was Thirty Two Thousand Three Hundred Dollars ($32,300.00), which he paid in full via a Chase Manhattan Bank Visa credit card. Based upon information and belief, that $32,300.00 consisted of the medical detoxification program ($3,000.00), the subsequent in-patient program

($28,500.00), JEFF'S "student money" ($300.00), books ($464.04) and sales tax.

13. After approximately forty-five minutes, MICHAEL left NARCONON'S Newport

Beach facility with only a credit card receipt for $32,300,00 and an invoice. He was not provided with any substantive information about the program, and given no literature or documentation about the purported treatment his son would be receiving. A copy of the credit card receipt and Invoice are attached hereto as Exhibit "A".

14. Immediately after MICHAEL left the facility, JEFF was instructed to sign a one

page admission paper which was filled out by the attendant at the admission desk, before being admitted.

15. After being admitted, JEFF was taken for an off-site medical evaluation, wherein

he informed the "physician" that he was currently under a psychiatric doctor's care and taking several prescription medications designed to treat a variety of conditions, including depression and other mental/mood disorders.

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COMPLAINT

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28 16. He was then driven to the off-site "medical" detoxification facility where his

parents had paid for him to remain for three (3) days. At no time during his stay at the detoxification facility was JEFF monitored by a qualified physician. Instead, he was "weaned" off his psychiatric prescription medications in only three days; he was unsupervised and unmonitored; he found the detox facility dirty, smelling of mildew, dilapidated, and generally unsanitary. On one occasion, he was forced to use his own t-shirt as a pillow case so that he would not be forced to lay his head on a blood-stained pillow.

17. During his stay at the detox facility JEFF repeatedly asked to see literature or

documentation about the program in which he had agreed to participate, and was repeatedly told the information would be provided to him "later."

18. On or about April 20, 2008, JEFF was transferred from the detox facility to the

NARCONON Newport Beach facility where based upon information and belief, the residential substance abuse recovery program was to take place. On or about that day, JEFF was introduced to and indoctrinated into the NARCONON treatment program based upon the teachings of L. Ron Hubbard and Scientology.

19. Based upon information and belief, NARCONON is a residential drug recovery

center closely affiliated with both the Association of Better Living (ABLE) and Scientology. NARCONON and ABLE receive funding from the Scientology organization as evidenced on the ABLE website's frequently asked questions section. Scientology is well-known as a cash flush

organization.

20. During the next 24 hours, JEFF was introduced to two "mentors" who had a

combined total of four (4) months of sobriety between them. He was provided with three paperback books written by L. Ron Hubbard (for which MICHAEL had paid $464.04) and a room in the "smoking" wing of the main house at NARCONON Newport Beach facility. JEFF is a non-smoker. JEFF was never provided with his $300.00 "student" spending money.

21. For the next 24 hours, JEFF, a devout follower of Judaism from birth, was

subjected to the teachings and made to participate in the practices of the Scientology-based program, including "assists" and "confronts" which were physically, spiritually, and emotionally

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COMPLAINT

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28 offensive to JEFF.

22. When JEFF asked to use to the telephone to contact MICHAEL he was refused.

At all times mentioned herein, JEFF felt that he was not free to leave the NARCONON facility, which made him feel unsafe and caused him emotional distress, which was exacerbated by the fact that he was no longer taking his prescription anti-depressant medication.

23. On April 21, 2008, JEFF snuck away from the watchful eye of his "mentor" at the

NARCONON Newport Beach facility, called his parents, who came immediately to retrieve him, and admitted him to another treatment facility where he completed his substance abuse recovery

treatment.

24. At no time prior to April 21, 2008, did JEFF or MICHAEL recerve any

information or literature, other than the invoice and credit card receipt attached hereto as Exhibit "A", from NARCONON.

25. Prior to April 21, 2008, neither JEFF, nor MICHAEL ever received a Customer

Service Policy or refund policy for Defendant, NARCONON.

26. At no time prior to payment of the fee, or pnor to JEFF'S leaving the

NARCONON Newport Beach facility, were Plaintiffs informed by anyone at NARCONON, either orally, or in writing, that the in-patient substance abuse treatment program was based on the teachings or followed the teachings of L. Ron Hubbard or Scientology.

27. Had MICHAEL or JEFF been informed that JEFF would be subjected to the

teachings of L. Ron Hubbard or Scientology prior to JEFF'S admission to the substance abuse treatment program, they absolutely and unequivocaJ1y would not have placed JEFF in the NARCONON Newport Beach facility, as the teachings of L. Ron Hubbard and Scientology are completely contradictory to the family's religious beliefs.

28. Had MICHAEL or JEFF been informed that JEFF would be subjected to the

teachings of L. Ron Hubbard or Scientology prior to JEFF'S admission to the substance abuse treatment program, they absolutely and unequivocally would not have paid $32,300.00 to NARCONON under any circumstances.

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COMPLAINT

1

MICHAEL immediately and repeatedly requested a refund of the portion of the

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2 fee paid in the amount of $29,275.00, including the $300 "student" money which was never

3 received by JEFF. MICHAEL made such requests to June Rosenberry, the Director of Client

4 Services at NARCONON.

5

On or about April 21, 2008, after JEFF had left the NARCONON Newport Beach

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6 facility, MICHAEL received a package via federal express which included NARCONON'S

7 Consumer Service Policy ("POLICY") and other documents purporting to be literature about the

8 NARCONON residential drug treatment facility. The POLICY was never provided to

9 MICHAEL or JEFF prior to April 21, 2008.

10

As a result of the failure to disclose the POLICY to MICHAEL and JEFF prior to

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11 April 21, 2008, Plaintiffs, and each of them, have been harmed, and continue to be harmed, in an

12 amount to be proven at the time of trial, but not less than $32,300.00.

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As a result of the failure by NARCONON to disclose the fact that its residential

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14 drug treatment program is founded on beliefs which violate their own deep religious beliefs,

15 Plaintiffs have been harmed, and continue to be harmed, in an amount to be proven at the time of

16 trial, but less than $32,300.00.

17 FIRST CAUSE OF ACTION

18 BREACH OF ORAL CONTRACT

19 (By All Plaintiffs Against NARCONON and DOES 1 through 25)

20

Plaintiffs reallege and reincorporate by reference each and every allegation

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21 contained in paragraphs 1 through 32 as though fully set forth herein.

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Plaintiffs and Defendant entered into an oral agreement at the time Plaintiff

23 MICHAEL paid to Defendant the admission fee for substance abuse recovery treatment for his

24 son, JEFF (hereinafter the "Agreement"). In consideration of MICHAEL'S payment in the

25 amount of $32,300.00, Defendants promised that JEFF would be treated with medically

26 supervised detoxification, that he would be "well taken care of," "in good hands," and that

27 NARCONON boasted a high success rate for persons with substance abuse problems, like JEFF.

28 They also promised that JEFF would have access to specific treatments to help him get through

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COMPLAINT

3

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As a direct and proximate result of each Defendant's breaches of the Agreement,

detoxification and through the substance abuse treatment program. Further NARCONON'S

2 website claims that the rehab center provides a safe environment and caring staff.

35.

Defendants materially breached this agreement when they refused to provide the

4 services promised under the Agreement and refused to refund the money paid as requested

5 repeatedly by MICHAEL after the material breaches were discovered.

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Plaintiff has performed all conditions, covenants, and promises required on its

7 part to be performed in accordance with the terms and conditions of the

8 Agreement with Defendants

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The continuing breaches by Defendants, and each of them, have and will

10 irreparably harm and impair Plaintiffs in an amount to be proven at the time of trial, but

11 exceeding $32,300.00.

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13 Plaintiffs have been required to incur, and will continue to incur, attorney's fees, costs and

14 expenses in connection with this lawsuit, in an amount to be proven at the time of trial

15 SECOND CAUSE OF ACTION

16 UNJUST ENRICHMENT

17 (By MICHAEL against NARCONON and DOES 1 through 50)

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Plaintiffs reallege and reincorporate by reference each and every allegation

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19 contained in paragraphs 1 through 38 as though fully set forth herein.

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Based upon the foregoing, Defendants, and each of them, received proceeds,

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21 including but not limited to the payment in the amount of$32,300.00 for services which were not

22 earned by NARCONON and to which it is not entitled, and has been unjustly enriched by its

23 receipt of them.

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MICHAEL seeks recovery of the amount to which NARCONON has been

25 unjustly enriched.

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The manner in which Defendants went about taking this money from MICHAEL

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27 was through duress, lies, and fraud which entitles MICHAEL to recover punitive damages in an

28 amount to be proven at the time of trial.

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COMPLAINT

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MICHAEL is entitled to an award of attorneys' fees related to recovering the

2 amount by which NARCONON was unjustly enriched.

3 THIRD CAUSE OF ACTION

4 FRAUD - INTENTIONAL CONCEALMENT

5 (By All Plaintiffs against NARCONON and DOES 1 through 50)

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Plaintiffs reallege and reincorporate by reference each and every allegation

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7 contained in paragraphs 1 through 43 as though fully set forth herein.

8

On or about April 18, 2008, Defendants and each of them, were aware of the fact

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9 that NARCONON'S substance abuse treatment program was based on the teachings of L. Ron

10 Hubbard and based upon Scientology.

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Furthermore, from about April 18,2008 through April 21, 2008, Defendants and

12 its agents and representatives, and each of them knew and were aware that the substance abuse

13 treatment program at NARCONON was based upon the teachings of L. Ron Hubbard and

14 Scientology.

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Despite JEFF'S repeated requests for information regarding the nature of the

16 purported treatment he was receiving, Defendant, its agents and representatives fraudulently

17 concealed the truth from JEFF subjecting him to beliefs and practices which were contrary to his

18 own deep religious beliefs.

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Notwithstanding the knowledge possessed by Defendant, its agents and

20 representatives and DOES 1 through 50, Defendant, its agents and representatives willfully,

21 intentionally and fraudulently concealed from MICHAEL and his son, JEFF, the manner and

22 method ofthe substance abuse treatment that JEFF would be receiving.

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Based on information and belief, such concealment occurred at the time

24 Defendant ordered, directed and required JEFF to be subjected to the teachings of L. Ron

25 Hubbard and Scientology.

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Ultimately, and upon learning the truth, JEFF was forced to re-evaluate his

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27 treatment options, and as a result of Defendant's fraudulent conduct and concealment, JEFF and

28 MICHAEL sustained damages.

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COMPLAfNT

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51.

Each of these acts and omissions by Defendant, including but not limited to

2 failing to reveal the method and manner of the substance abuse treatment center and was done by

3 Defendant falsely and fraudulently with intent to induce Plaintiff to admit JEFF into its facility,

4 and with the intention to induce MICHAEL to pay $32,300.00 to Defendant. Plaintiff was

5 ignorant of the truth, and would not have subjected JEFF to the aforementioned had known the

6 true facts.

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In undertaking the conduct described above, Defendants, and each of them, acted

8 in willful and conscious disregard of the rights, safety, welfare, or best interests of JEFF, and

9 therefore, of his father, MICHAEL.

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As a direct and legal result of the fraudulent concealment of Defendants, and each

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11 of them as described above, JEFF and MICHAEL were harmed in an amount to be proven at the

12 time of trial.

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As a result of such conduct, Defendants, and each of them, acted fraudulently,

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14 willfully, maliciously, and oppressively, as defined in California Civil Code § 3294, and

15 Plaintiffs are entitled to punitive damages from Defendants, and each of them.

16 FOURTH CAUSE OF ACTION

17 FRA un - MISREPRESENTATION

18 (By All Plaintiffs against NARCONON and DOES 1 through 50)

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Plaintiffs reallege and reincorporate by reference each and every allegation

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20 contained in paragraphs 1 through 54 as though fully set forth herein.

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On or about April 18, 2008, Defendants and each of them made multiple

22 misrepresentations to MICHAEL, JEFF, and Linda Jacobs regarding the "medical"

23 detoxification and in-patient substance abuse recovery treatment which would purportedly be

24 provided to JEFF in exchange for $32,300.00. Defendants knew these representations to be

2S false, and the representations were made with the intent to defraud and deceive Plaintiffs, and

26 with the intent to induce MICHAEL to purchase the services, on behalf of JEFF, that Plaintiffs

27 were promised.

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When Defendants entered into the Agreement with Plaintiffs, Defendants knew

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COMPLAINT

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In reliance upon Defendant's representations, JEFF was induced into admission

that they in fact would use this arrangement to keep for themselves MICHAEL'S $32,300.00,

2 regardless of whether JEFF was ever to receive the promised services, and Defendants, its

3 agents, representatives, and employees concealed this information from Plaintiffs.

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At the time the representations were made by Defendants, Plaintiffs were ignorant

5 of their falsity.

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7 into the NARCONON Newport Beach facility, and MICHAEL was induced into entering into an

8 Agreement with Defendants promising the services set forth herein.

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Had Plaintiffs known the actual facts about the services and the provider of the

10 services, Plaintiffs would not have entered into any such Agreement, and not acted in the manner

11 alleged herein.

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Plaintiffs' reliance on the Defendant's representations were justified and

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13 reasonable because of their belief that Defendants were making representations to Plaintiffs

14 fairly, honestly and in good faith, and because there was nothing that led Plaintiffs to believe that

15 the Defendants would defraud and exploit Plaintiffs.

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As a proximate result of Defendants' fraud and deceit, and the alleged facts

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17 herein, Plaintiffs have been damaged in an amount according to proof at trial, but exceeding

18 $32,300.00.

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As a result of such conduct, Defendants, and each of them, acted fraudulently,

20 willfully, maliciously, and oppressively, as defined in California Civil Code § 3294, and

21 Plaintiffs are entitled to punitive damages from Defendants, and each of them.

22 FIFTH CAUSE OF ACTION

23 CONVERSION

24 (By MICHAEL Against NARCONON and DOES 1 through 25)

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Plaintiffs reallege and reincorporate by reference each and every allegation

26 contained in paragraphs 1 through 63 as though fully set forth herein.

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As a result of Defendant's material breaches of the Agreement, Defendant, and

28 each of them, had a duty to repay MICHAEL the entire amount paid to Defendant under the

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COMPLAINT

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66. Plaintiffs never consented to, approved, waived, or ratified any such conversion

by Defendants.

67. MICHAEL took all reasonable steps to ensure that he would be paid all sums due

him from Defendant, and each of them, in accordance with the Agreement between Plaintiffs and Defendant, including asking for the return of the monies paid, but Defendant has refused to return the money to MICHAEL, its rightful owner.

68. MICHAEL is entitled to an award of costs, including attorneys fees, incurred in

recovering the amounts converted.

69. Defendant's actions were fraudulent, malicious and oppressive and Plaintiff is

entitled to an award of punitive damages.

SIXTH CAUSE OF ACTION

UNFAIR COMPETITION/FRAUDULENT ACTS OR PRACTICES

California Business and Professions Code §§17200 et seq. (By Plaintiffs Against All Defendants and DOES 1 through 50)

70. Plaintiffs reallege and reincorporate by reference each and every allegation

contained in paragraphs 1 through 69 as though fully set forth herein.

71. Defendants' unlawful and fraudulent conduct constitutes unfair, unlawful, and

fraudulent business practices in violation of California Business and Professions Code § § 17200 et seq. which have caused harm to Plaintiffs, including monetary damagers and emotional distress.

72. Defendant, through its agents, representatives, and employees made promises and

misrepresentations to Plaintiffs, MICHAEL and JEFF, and Linda Jacobs that JEFF would receive "medical" detoxification and in-patient substance abuse recovery treatment as described hereinabove, and incorporated herein by reference. These misrepresentations were made with the intent to defraud and deceive Plaintiffs, and with the intent to induce Plaintiffs to purchase the

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COMPLAINT

1 services that Plaintiffs were promised in the amount of $32,300.00. Defendants statements were

2 likely to deceive, and did in fact deceive Plaintiffs, proximately causing substantial injury to

3 Plaintiffs.

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The aforementioned wrongful acts have proximately caused and will continue to

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5 cause Plaintiffs substantial injury, by inducing Plaintiffs to enter into an Agreement, wherein

6 Plaintiffs paid $32,300.00 which Defendants knew that they in fact would keep for themselves

7 regardless of whether Plaintiffs were entitled to a refund as part of the Agreement, and concealed

8 this information from Plaintiffs.

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As part of their strategy, Defendants induced JEFF to sign documents that he did

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10 not understand or comprehend at a time when he was vulnerable and confused.

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As part of their strategy, Defendants induced MICHAEL to pay $32,300.00 for a

12 substance abuse treatment program without providing him with literature or documentation other

13 than a credit card receipt and an invoice at the time JEFF was admitted for treatment.

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The foregoing conduct of Defendants constitutes unfair business practices and/or

15 unfair competition under California Business and Professions Code §§ 17200, et seq.

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Defendants have acquired money, property or other benefits as a direct and

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17 proximate result of their unfair competition andlor unfair business practices directed at

18 Plaintiffs, and in an amount to be proven at trial.

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Defendants, and each of them, should be ordered to restore and/or disgorge to

20 Plaintiffs all money or property or other benefits gained by them as a direct and proximate result

21 of Defendant's unfair competition and/or unfair business practices directed at Plaintiffs.

22 PRAYER FOR RELIEF

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That Plaintiff receive monetary damages against each Defendant in amounts to be

24 determined at trial;

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That Defendants each be held to have converted MICHAEL'S money in the

26 amount of $32,300.00;

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That Defendants each be held to have conducted unfair business practices;

That Defendants be ordered to restore andlor disgorge to Plaintiffs all money or

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COMPLAINT

2 3 4 5 6

1 property or benefits gained by them;

5. 6. 7. 8. 9.

That Plaintiffs be awarded attorney's fees as against each Defendant; That Plaintiffs receive punitive damages as against each Defendant; For the interest to the extent allowable by law;

For Plaintiffs costs of suit herein incurred in this action; and

For any other relief as the Court may deem appropriate.

7 JURY TRIAL DEMANDED

8 Plaintiffs hereby demand a trial by jury of all issues so triable.

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10 Dated: August {) 3 ,2009

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REINMILLER LAW FIRM

,daf#./2 g_ Q

TRAC . REINMILLER

Attorneys for Plaintiffs, MICHAEL JACOBS and JEFF JACOBS

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COMPLAINT

EXHIBIT

EXHIBIT "A"

I •• <:"l'1'-

.II'IIIIH1.IHII:I

WI 001/007

,., 'i,'

4174l<&tapriu CfMleN Suite 102 T~CA 92590

_.

NARCIJt.IOtl STHlN CAL 1m H 0CfIW 00lT mPaRT BEACH CA 92663

Phone: 8004OS..t409 FlOC' 'Sl~~9819

cn~='''innrrlf'LnV1

Invoice

DAlE: e.t1.M9 WE! .13121: 51 IIlRII 30i"3916SZ428 mIl! 0081 TfR.If: 800l

S-A,L-E-S D-R-A-F - T

REf: 99Ell iRTI:Ii: 002

CD 1i'PE! VI TR TYPE: PR

INV ~l 123

r " r Ii L ! ta2'3OO,98

Date:~18J)8

aill To: Mike &:Lmda:Taeobs 9 RucGtamlVilla

. 'Newport, Beach;· CA 92060

/tf:T: DB_4m £XP: _ I\P: ~l9C

CAIiIlI1EItlER' A®BLEDGEs RECEIPT IF ~JIIIc:IM S£JiVICB IN 1l£ MlMT OF ImON AmI fIIiIIW TO TiI)lS ~ FORTH BV TI£ WlTH·TII ISSID

~To: 'lVarooaon,Southetn'Califbtnia .4t'743.~CirclcN .. Suite 102 .. T_\MCA92S90

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. " "' . Date .. ProllramCoat A.mQDDtPaid 8aIanee
ff~Ol1'Program 44l4Js $28$00.00 $ -O~
.... : . ':. ..; ":;., :~, ,. $32.000.00
Boob 5464.04 PaifJluFull
Medical Detox
$3;000.00.
Sales Tax s 35.96
Total $ 29tooO',00 Narconon is a 501 (c)3 Corp. Please provide your

Tax adVisovtViih a copy oftbis invoice fotanypotential tax deduction

Thank You, .:O~et.Carmichael

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