Nardella v. Narconon: Complaint

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 1 of 14
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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
DISTRICT OF NEVADA
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DIANNA NARDELLA, a Maryland Citizen; and

CHARLES NARDELLA, a Maryland Citizen,
Case No.
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Plaintiffs,
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vs.
COMPLAINT AND JURY DEMAND
NARCONON FRESH START d/b/a RAINBOW
CANYON RETREAT, a California Corporation;
ASSOCIATION FOR BETTER LIVING AND
EDUCATION INTERNATIONAL;
NARCONON WESTERN UNITED STATES;
NARCONON INTERNATIONAL, and DOES
1-100, ROE Corporations I X, inclusive,
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Defendants.
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Plaintiffs Dianna and Charles Nardella (Plaintiffs), by and through their attorney Ryan
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Hamilton of Hamilton Law, LLC, file their Complaint and Jury Demand:
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I.
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PARTIES
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1.
Plaintiffs are residents of, and for the purposes of determining federal diversity jurisdiction
are, citizens of Maryland.

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2.
Defendant Narconon Fresh Start (hereafter 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 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.
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in Los Angeles, California.
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over the time, manner, and method of Fresh Starts operations.
Defendant Narconon International (NI) is a California corporation with its headquarters
NI is the principal and licensor of Defendant Narconon Fresh Start. NI exercises control
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NI was doing business in the State of Nevada by and through its agent and
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subsidiary/licensee Defendant Narconon Fresh Start. NI may be served with process through its
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registered agent, Timothy Bowles, 1 South Fair Oaks Avenue, Pasadena, CA 91105.
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(ABLE). ABLE oversees the drug rehabilitation, education, and criminal justice activities of the
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Church of Scientology including, but not limited to, Fresh Start and NI.
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in Los Angeles, California.
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actively managing their daily operations, including conducting inspections of Narconon centers
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and creating, licensing, and approving their marketing materials.
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9.
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International and Narconon Fresh Start. ABLE may be served with process through its registered
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agent, Timothy Bowles, 1 South Fair Oaks Avenue, Pasadena, CA 91105.
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State of California with its headquarters in Los Angeles, California.
Fresh Start and NI are subsidiaries of the Association for Better Living and Education
Defendant ABLE is a corporation registered in the State of California with its headquarters
ABLE controls the time, manner, and method of NIs and Fresh Starts businesses by
ABLE transacts business in the State of Nevada by and through its agents, Narconon
Defendant Narconon Western United States (Western) is a corporation registered in the
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Western controls the time, manner, and method of Fresh Starts business by actively
managing its daily operations, and creating and approving their marketing materials.
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through its registered agent, Luria K. Dion, 249 N. Brand Blvd #384, Glendale, CA 91203.
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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.
Western transacts business in the state of California and may be served with process
Plaintiffs are unaware of the true names and capacities, whether individual, corporate,
II.
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JURISDICTION AND VENUE
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This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1332. The amount in
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controversy exceeds $75,000.00, and there is complete diversity between the parties.
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15.
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of the events and omissions giving rise to this lawsuit occurred in this District, and the Court has
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personal jurisdiction over each of the parties as alleged throughout this Complaint.
Venue is proper in this Court pursuant to 28 U.S.C. 1391(a) because a substantial portion
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III.
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FACTUAL ALLEGATIONS
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On or about December 22, 2011, Plaintiff Dianna Nardella was looking for a drug
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rehabilitation facility for her son, Plaintiff Charles Nardella.
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Dianna searched on the Internet and contacted Narconon Fresh Start.
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Dianna spoke with Narconon representative Ryan Warczak.
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Dianna explained to Warczak that her son had recently been a passenger in automobile
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accident in which three of his friends had been killed and her son was the lone survivor. Dianna
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further explained that her son needed a rehabilitation program that provided both substance abuse
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treatment and counseling for his grief and depression related to the auto accident.
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Warczak then knowingly made several material false representations of fact to Dianna.
Narconon Fresh Starts website, www.freshstart.net, also made many of these same false
representations.
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counseling for grief and depression as well as substance abuse treatment.
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involve counseling. By design, the Narconon program contains no counseling. Each patient
undergoing the Narconon program receives the same eight course materials based on the works of
L. Ron Hubbard, founder of the Scientology religion.
First, Warczak falsely represented to Dianna that the Narconon program provided both
Narconon Fresh Start has admitted in other cases that the Narconon program does not
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The materials in the course books are L. Ron Hubbard technology. In Narconon and
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Scientology, L. Ron Hubbard technology is to be applied exactly as written. Accordingly, patients
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undergoing the Narconon program are not allowed to go beyond or deviate from the technology
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in the Narconon course books.
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than 76 % success rate.
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despite knowing this is false.
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advised the Narconon Freedom Center in Michigan not to claim the high success rate in
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responding to a Better Business Bureau complaint. Ms. Arcabascio advised Narconon Freedom
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do not say we have 70% success (we do not have scientific evidence of it). See email from Ms.
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Arcabascio, attached hereto as Exhibit A.
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27.
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her sons drug cravings by having Charles undergo Fresh Starts sauna detoxifying program, the
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New Life Detoxification Program.
Second, Warczak falsely represented that the Narconon treatment program had a better
Defendants have routinely advertised that the Narconon program has a 76% success rate
For example, the Director of Legal Affairs for Narconon International, Claudia Arcabascio,
Third, Warczak falsely represented to Dianna that Fresh Start would reduce or eliminate
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Warczak claimed that the New Life Detoxification Program has been scientifically shown
to flush out residual drug toxins stored in fatty tissues to thereby reduce or eliminate a patients
drug cravings.
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Detoxification Program reduces or eliminates drug cravings. In fact, there is no scientific evidence
the New Life Detoxification Program flushes out drug toxins whatsoever.
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eliminate an addicts drug cravings.
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As Defendants are well aware, there is no scientific evidence that the New Life
Fresh Starts website also made this false claim that its sauna program can reduce or
Fourth, Warczak falsely represented that the treatment program offered at Fresh Start is
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secular and does not involve the study or practice of religion.
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practice of the Scientology religion.
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scriptures. The Narconon treatment program has patients unwittingly study and practice
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introductory Scientology under the premise that Scientology can treat or cure substance abuse.
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the Eight Dynamics of Existence, the Cycle of Communication, the Conditions of Existence, the
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Suppressive Person doctrine, Overts and Withholds, the A-R-C triangle, and clearing words and
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study tech.
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doctrines by, for example, making clay sculptures related to those doctrines.
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Scientology ritual known as the Purification Rundown.
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order to move up The Bridge To Total Freedom, Scientologys spiritual journey.
To the contrary, the Narconon treatment program is comprised entirely of the study and
The materials in the eight Narconon course books come directly from Scientologys
The Narconon course books teach foundational Scientology concepts and doctrines such as
The Narconon course books have patients demonstrate their understanding of Scientology
Narconons sauna program, the New Life Detoxification Program, is actually a
Completion of the Purification Rundown is a required ritual for practicing Scientologists
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fee of $33,000.00 for Charless participation in the program in Caliente, Nevada. See Exhibit B,
Invoice from Narconon Fresh Start.
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promised and for which Plaintiffs paid a substantial sum of money. Instead, Charles received only
Scientology indoctrination.
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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
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document shows that when a patient finishes the Narconon program, the patient is to be route[d]
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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
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Technical Line-Up is attached hereto as Exhibit C.
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considers its program to be an initial step into getting on Scientologys Bridge to Total
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Freedom, the key spiritual journey that practitioners of the Scientology religion undertake. See,
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e.g., Narconon News, 1974, Volume 6, Issue 3: Narconon Is The Bridge to The Bridge, attached
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hereto as Exhibit D.
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to Scientology around its offices. At Fresh Starts headquarters in Glendale, California, hangs a
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plaque from the Church of Scientology that thanks Larry Trahant and The Narconon Fresh Start
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Team for introducing patients to L. Ron Hubbard and The Bridge. The writing on the plaque
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provides, in relevant part:
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Based on these representations, Dianna admitted Charles to Fresh Start and paid an upfront
At Narconon Fresh Start, Charles did not receive any of the treatment Plaintiffs had been
Narconon documents indicate that the Narconon program is used to recruit patients into the
Narconon considers its program to be the Bridge to the Bridge. That is, Narconon
Narconon Fresh Start displays tokens of recognition it has received for introducing patients
Larry and his dynamic team at Narconon Fresh Start are hereby
warmly thanked and highly commended for their dedication and
hard work. They give us tremendous back up in introducing LRH to
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the world and are saving lives on a daily basis. There are thousands
of beings who have taken their first steps on The Bridge, thanks to
the compassion and efforts of this team.
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A photo of this plaque is attached hereto as Exhibit E.

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Scientology publications show that the Narconon program is part of Scientologys plan to
clear the planet. (To go clear is the ultimate spiritual goal for a Scientologist, achieved after
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one goes up the Bridge to Total Freedom.) The document attached hereto as Exhibit F, shows a
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Church of Scientology, or an Org as its known, with an arrow directed at the Narconon
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Jumping Man logo. The document reads:
The question is not how to clear an individual, its how to clear a

civilization by making every one of our orgs a central
organization responsible for every sector of Scientology activities
across its [sic] entire geographic zone.
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In other words, the Church of Scientology is supposed to direct Narconon to achieve Scientologys
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spiritual goal of clearing the planet.
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Hubbards technology to unwitting patients seeking drug rehabilitation. This is exactly as the
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Church of Scientology directed as part of its Social Coordination Strategy. Scientology
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explicitly outlined this strategy in an urgent Executive Directive from the Authorization,
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Verification, and Correction Department of its Religious Technology Center. The Executive
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Directive outlining the Social Coordination Strategy is attached hereto as Exhibit G (hereafter
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the SOCO Directive).
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Narconon Fresh Start is using the Narconon program to introduce Scientology and L. Ron
The SOCO Directive instructed all SOCO GROUPS, which includes Narconon, as follows:
YOU ARE THERE TO SELL LRHs TECH TO THE SOCIETY
AND GET IT USED, AS THE TECH. You do this through a
SMOOTH JOB OF PROMTIONAL ORGANIZATION FRONT
GROUPS, CORPORATIONS, FIELD WORKERS, ETC.
(emphases in original).
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The SOCO Directive expressly directed the use of front groups to introduce L. Ron Hubbards
technology, i.e., Scientology, to society.
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counseling for his grief and depression.
Because of Defendants deception, Charles did not receive any substance treatment or
RELATIONSHIP AMONG DEFENDANTS
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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:
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nearly every aspect of Narconon Fresh Starts business activities.
ABLE, NI and Western heavily influence Narconon Fresh Start and govern and control
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NI publishes operations manuals and requires that individual Narconon centers such as
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Narconon Fresh Start d/b/a Rainbow Canyon Retreat abide by these manuals in their operations.
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These operations manuals are called Running An Effective Narconon Center and Opening A
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Successful Narconon Center.
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Narconon Fresh Start employees. Narconon Fresh Start cannot demote, transfer, or dismiss a
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permanent staff member at Narconon Fresh Start without approval from the Senior Director of
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Administration at NI.
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Narconon Fresh Start. If a Narconon Fresh Start staff member does not meet the qualifications of a
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staff member, the staff member may petition the Senior Director of Administration at NI to remain
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on staff.
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materials that make it hard or impossible for her to do her job, she may file a Job Endangerment
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Chit with the Ethics Department at NI. NI and Western then investigate and work to resolve the
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staff members issue.
These manuals show that NI, ABLE, and Western have the ultimate authority over
NI, ABLE and Western have the ultimate authority over the hiring of staff members at
If a staff member at Narconon Fresh Start believes she has been given orders or denied
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The operations manuals require staff members at Narconon Fresh Start to report
misconduct and nonoptimum conduct to the Quality Control Supervisor at NI. NI and Western
investigate misconduct at Narconon Fresh Start and may take disciplinary actions against its staff
members.
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Start.
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more than 40 different metrics. NI and Western review these weekly reports and order changes at
Narconon Fresh Start based on increases or decreases in the statistics in the reports.
NI and Western receive ten percent of the weekly gross income from Narconon Fresh
NI requires Narconon Fresh Start to send it detailed weekly reports containing statistics of
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NI, Western, and ABLE require that Narconon Fresh Start receive approval on all
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promotional materials before Fresh Start disseminates them. Further, Fresh Start must obtain
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approval as to its Internet websites from NI, Western, and ABLE before the sites go live.
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NI, Western and ABLE dictate the contents of those advertising materials.
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monies from the gross income are used to purchase new premises and also as a cushion to salvage
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the organization in dire circumstances. The building fund is under the control of NI.
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inspections entail NI, Western, and ABLE monitoring and correcting the manner in which
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Narconon Fresh Start delivers the Narconon treatment program to patients at Fresh Start. NI,
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Western, and ABLE instruct staff at Fresh Start as to the exact manner in which they are to
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perform their services and deliver the Narconon treatment program.
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NI and ABLE also publish all training materials for Narconon Fresh Start.
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This includes seven different training materials on subjects ranging from the Narconon
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sauna program to overseeing to delivering the Narconon treatment program.
NI, Western and ABLE also assist in creating Narconon Fresh Starts advertising materials.
NI requires that Narconon Fresh Start maintain a building account fund in which weekly
NI, Western and ABLE conduct tech inspections at Narconon Fresh Start. These
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NI, Western, and ABLE micro-manage individual Narconon centers such Fresh Start d/b/a
Rainbow Canyon Retreat to such a large extent that they publish the exact materials authorized to
be sold in an individual Narconon centers bookstore.
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good photos of L. Ron Hubbard visible in every center and that materials are available to students
and staff as to L. Ron Hubbards contributions in the field of alcohol and drug rehabilitation.
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legal problems, including patient requests for refunds and complaints to the Better Business
Bureau. In addition, NI, Western, and ABLE work to combat negative publicity for Fresh Start.
Further, the NI Director of Technology and Approval demands and ensures that there are
NI, Western, and ABLE work with individual Narconon centers such as Fresh Start on
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NI, Western, and ABLE are intimately involved in the day-to-day operations of Narconon
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Fresh Start. NI, Western, and ABLE have the final authority over all decisions at Narconon Fresh
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Start relating to hiring and firing, delivery of services, finances, advertising, training, and general
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operations.
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the Scientology religion under the guise of providing drug rehabilitation.
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NI, Western, and ABLE all are principals served by their agent, Fresh Start.
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Persons from the Narconon network such as Defendants herein recommend that families
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use on of Narconons recommended interventionists. Because the interventionist receives the
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referral from Narconon, the interventionist does not inform the family of Narconons connections
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to Scientology.
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associated with Scientology.
NI, Western, and ABLE perpetrate use the Narconon program to recruit for and promote
The Narconon network also warns interventionists against telling families that Narconon is
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FIRST CLAIM FOR RELIEF
BREACH OF CONTRACT
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forth in the preceding paragraphs and further allege as follows:
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exchange for consideration, to provide secular, residential drug and alcohol treatment to Charles
Nardella.
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drug and alcohol treatment; and (ii) providing Scientology in lieu of drug and alcohol treatment.
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Plaintiffs and Defendants were bound by a Contract whereby Defendant agreed, in
Defendants breached this contract by, inter alia: (i) failing to provide services constituting
Defendants breaches have caused Plaintiffs to suffer damages in excess of $75,000.00.
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SECOND CLAIM FOR RELIEF
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BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING
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Charles Nardella contained an implied covenant of good faith and fair dealing.
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expectations by, inter alia: (1) having Charles Nardella unwittingly study and practice Scientology
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in lieu of engaging in drug treatment; and (2) attempting to have Charles Nardella surrender his
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legal rights in exchange for services for which Plaintiffs had already provided consideration; and
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(3) persuading Dianna Nardella to send Charles to Fresh Start with promises that Narconons
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sauna program would reduce or eliminate his drug cravings by flushing toxins and then asking
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Charles at Fresh Start to sign an acknowledgement that the sauna program is not a medical
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program and that it provides no physical gains.
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The contract Plaintiffs entered into with Defendants for Defendants to provide treatment to
Defendants acted unfaithfully to the purpose of the contract and Plaintiffs justified
As a consequence of Defendants breaches, Plaintiffs have suffered damages.

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THIRD CLAIM FOR RELIEF
CIVIL CONSPIRACY
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indoctrinating and recruiting Plaintiff Charles Nardella into Scientology under the guise of
providing him with drug treatment.
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Plaintiff Charles Nardella for which a medical license was required under NRS 630.160. Such
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procedures included having Charles Nardella sit in a sauna for five hours per day for five weeks
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and take extreme doses of Niacin and vitamins without any medical supervision.
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objectives to harm Plaintiff Charles Nardella, he has been harmed.
Defendants intended to act in concert to accomplish the unlawful objectives of
Defendants further acted in concert to have non-physicians perform medical procedures on
As a proximate result of Defendants intentional actions in concert to accomplish unlawful
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FOURTH CLAIM FOR RELIEF
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FRAUD CLAIMS PURSUANT TO NRS 41.600
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82.
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fraud.
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598.0915 to 598.0925, inclusive.
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services as advertised, but provided Scientology instead.
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programs success rate.
By reason of Defendants actions complained of herein, Plaintiffs are victims of consumer
Defendants have engaged in numerous deceptive trade practices as defined in NRS
Defendants advertised substance abuse treatment services with the intent not to sell those
Defendants knowingly made false representations about the Narconon treatment
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Defendants used a bait and switch scheme whereby Defendants advertised extensive
substance abuse counseling and then delivered only Scientology teaching and dangerous
Scientology rituals.
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were selling such as the fact that Defendants treatment program consisted of Scientology
doctrines and practices.
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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
Defendants failed to disclose material facts to Plaintiffs about the services Defendants
Defendants made assertions of scientific, clinical, or quantifiable fact without having
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eliminate drug cravings.
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as a result, have lost $33,000.00. and Plaintiff Charles Nardella was deprived of the opportunity to
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receive genuine addiction treatment and counseling for grief and depression.
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91.
Defendants deceptive trade practices are likely to continue without court intervention.
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92.
Plaintiffs are entitled to all available relief under NRS 41.600 including Plaintiffs
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attorneys fees and costs of this action, Plaintiffs damages, and an injunction restraining
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Defendants from further engaging in the deceptive trade practices complained of herein.
Plaintiffs have been the victims of Defendants deceptive trade practices listed above and,
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DEMAND FOR JURY TRIAL
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Plaintiffs demand a jury trial on all issues triable.
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PRAYER FOR RELIEF
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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;
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B. Compensation for special, general, and treble damages;
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C. Reasonable attorneys fees and costs of suit;

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D. Interest at the statutory rate;
E. Punitive or exemplary damages against Defendants; and
F. Injunctive relief prohibiting Defendants from further engaging in deceptive trade practices.
DATED this 5th day of January, 2015.
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
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Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 1 of 14

UNITED STATES DISTRICT COURT

DIANNA NARDELLA, a Maryland Citizen; and

are, citizens of Maryland.

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 2 of 14

in Los Angeles, California.

over the time, manner, and method of Fresh Starts operations.

Defendant Narconon International (NI) is a California corporation with its headquarters

in Los Angeles, California.

and creating, licensing, and approving their marketing materials.

agent, Timothy Bowles, 1 South Fair Oaks Avenue, Pasadena, CA 91105.

State of California with its headquarters in Los Angeles, California.

Defendant Narconon Western United States (Western) is a corporation registered in the

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 3 of 14

when the identities of these Defendants are ascertained.

JURISDICTION AND VENUE

rehabilitation facility for her son, Plaintiff Charles Nardella.

Dianna searched on the Internet and contacted Narconon Fresh Start.

Dianna spoke with Narconon representative Ryan Warczak.

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 4 of 14

counseling for grief and depression as well as substance abuse treatment.

L. Ron Hubbard, founder of the Scientology religion.

Scientology, L. Ron Hubbard technology is to be applied exactly as written. Accordingly, patients

in the Narconon course books.

than 76 % success rate.

despite knowing this is false.

Arcabascio, attached hereto as Exhibit A.

New Life Detoxification Program.

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 5 of 14

eliminate an addicts drug cravings.

secular and does not involve the study or practice of religion.

practice of the Scientology religion.

Scientology ritual known as the Purification Rundown.

order to move up The Bridge To Total Freedom, Scientologys spiritual journey.

Narconons sauna program, the New Life Detoxification Program, is actually a

Completion of the Purification Rundown is a required ritual for practicing Scientologists

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 6 of 14

Invoice from Narconon Fresh Start.

Technical Line-Up is attached hereto as Exhibit C.

provides, in relevant part:

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 7 of 14

A photo of this plaque is attached hereto as Exhibit E.

Jumping Man logo. The document reads:

The question is not how to clear an individual, its how to clear a

spiritual goal of clearing the planet.

Church of Scientology directed as part of its Social Coordination Strategy. Scientology

the SOCO Directive).

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 8 of 14

technology, i.e., Scientology, to society.

counseling for his grief and depression.

RELATIONSHIP AMONG DEFENDANTS

forth in the preceding paragraphs and further alleges as follows:

nearly every aspect of Narconon Fresh Starts business activities.

Successful Narconon Center.

staff members issue.

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 9 of 14

perform their services and deliver the Narconon treatment program.

sauna program to overseeing to delivering the Narconon treatment program.

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 10 of 14

be sold in an individual Narconon centers bookstore.

the Scientology religion under the guise of providing drug rehabilitation.

use on of Narconons recommended interventionists. Because the interventionist receives the

associated with Scientology.

Case 2:15-cv-00011 Document 1 Filed 01/05/15 Page 11 of 14