IN THE CIRCUIT COURT FOR THE 11THJUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDACIVIL DIVISIONCase No.:JANE DOE,Plaintiff,v.CHURCH OF SCIENTOLOGY FLAGSERVICE ORGANIZATION, INC., a Floridacorporation; CLEARWATER ACADEMY,INC., a Florida corporation; THE CHURCHOF SCIENTOLOGY INTERNATIONAL, aCalifornia corporation; RELIGIOUSTECHNOLOGY CENTER, a Californiacorporation; and DAVID MISCAVIGE, aCalifornia resident;Defendants. _____________________________________/
COMPLAINT FOR DAMAGESINTRODUCTION
This case is brought against the Defendant Organizations of Scientology; its leader, DavidMiscavige; and Clearwater Academy, a Scientology school, for the continued sexual abuse thatJane Doe suffered at the hands of Defendants’ employees, members, agents, and/or representatives, and, thereafter, because the Defendants conspired to and did cover up thosecrimes. When Jane Doe came forward to make Defendants’ crimes known to the public, theDefendants continued their conspiracy against Plaintiff and systematically stalked, harassed,invaded her privacy, and intentionally caused her emotional distress to silence and intimidate her.
Filing # 95934563 E-Filed 09/18/2019 04:50:11 PM
2
PARTIES
1. Plaintiff Jane Doe is a female whose name is not contained in this Complaint to protect her privacy and identity as she incurred injuries and damages of a sensitive nature as aresult of Defendants’ intentional acts, described below. Information which could identify JaneDoe is not contained herein. Plaintiff may be contacted through her counsel. There exists goodcause for Plaintiff to use a pseudonym due to the harmful effect of the public disclosure of her identity and the harm inflicted by the Defendants upon her, including the harm inflicted upon her while she was a child. Plaintiff fears physical and mental reprisals if her identity is revealed. Shehas not engaged in any action to compromise her anonymity or failed to take action which would preserve her anonymity. Plaintiff’s undersigned counsel will provide the identityof Plaintiff to allDefendants. As such, Defendants suffer no prejudice as a result of concealing her identity in theComplaint.2. Defendant Church of Scientology Flag Service Organization, Inc. (“Flag Service”)is a Florida corporation with its principal place of business in Clearwater, Florida.3. At all times material, Robert Potters, 911 Chestnut Street, Clearwater, Florida33756, is and was the Registered Agent for Flag Service and may accept service of process under Florida Statutes section 48.091.4. Defendant Clearwater Academy, Inc. (“Clearwater Academy”) is a Floridacorporation with its principal place of business in Clearwater, Florida.5. At all times material, Jim Zwers, 801 Drew Street, Clearwater, Florida 33755, isand was the Registered Agent for Clearwater Academy and may accept service of process under Florida Statutes section 48.091.
3
6. Defendant The Church of Scientology International (“CSI”) is a Californiacorporation with its principal place of business in California.7. Defendant Religious Technology Center (“RTC”) is a California corporation withits principal place of business in California.8. Hereinafter, when referring to Flag Service, CSI, and RTC collectively, the phrase“Institutional Defendants” will be used.9. Defendant David Miscavige is and was a resident of California.
JURISDICTION AND VENUE
10. Defendants are subject to personal jurisdiction in Florida because, among other things, theyreside in Miami-Dade County, Florida; engage in substantial and not isolated businessactivity on a continuous and systematic basis in the State of Florida; and/or operate, conduct,engage in, or carry on a business or business venture in this State, or have an office or agency inthis State.11. Venue is proper in Miami-Dade County, Florida pursuant to Florida Statutessection 47.051, as Defendants CSI and RTC, who do business in this state, reside and/or haveagents and representatives in Miami-Dade County, Florida.
FACTUAL HISTORY
12. The Institutional Defendants, along with a network of organizations that operateunder their control, make up what is known to the public as “The Church of Scientology” or “Scientology.”13. Defendant Miscavige, known as “Chairman of the Board,” is the leader of “TheChurch of Scientology.” Defendant Miscavige directs, operates, supervises, and/or controls theInstitutional Defendants, including their suborganizations or divisions, and Clearwater Academy.