Вы находитесь на странице: 1из 16

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 1 of 16

1
2
3
4

Ryan A. Hamilton
NV 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

5
6

Attorney for the Plaintiffs,


Paul and Carla Savoie

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

9
10

PAUL SAVOIE, an individual; and CARLA


SAVOIE, an individual,
Case No.
Plaintiffs,

11

vs.

12
13
14
15
16
17

COMPLAINT AND JURY DEMAND


NARCONON FRESH START d/b/a
RAINBOW CANYON RETREAT;
ASSOCIATION FOR BETTER LIVING AND
EDUCATION INTERNATIONAL;
NARCONON INTERNATIONAL;
NARCONON WESTERN UNITED STATES
and DOES 1-100, ROE Corporations I X,
inclusive,
Defendants.

18
19
20
21

Plaintiffs Paul Savoie and Carla Savoie (Plaintiffs), by and through counsel, allege the
following:

22

I.

23
24
25

PARTIES
1.

Plaintiffs Paul Savoie and Carla Savoie are residents of, and for the purposes of

determining federal diversity jurisdiction citizens of, Saskatoon, Canada.


1

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 2 of 16

Defendant Narconon Fresh Start (hereafter Fresh Start), is, and at all times relevant to

2.

this Complaint was, a corporation incorporated under the laws of, and with its principal place of

business in, the State of California. Defendant 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.

3.

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

4.

managing its daily operations, and creating and approving their marketing materials.

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

Western controls the time, manner, and method of Fresh Starts business by actively

10

5.

Defendant Narconon International is a California corporation with its headquarters in Los

11

Angeles, California.

12

6.

13

its agent and subsidiary/licensee Defendant Narconon Fresh Start. NI may be served with process

14

through its registered agent, Timothy Bowles, One South Fair Oaks Avenue, Pasadena, California

15

91105.

16

7.

17

Education (ABLE). ABLE oversees the drug rehabilitation, education, and criminal justice

18

activities of the Church of Scientology including, but not limited to, Fresh Start and Narconon

19

International.

20

8.

21

in Los Angeles, California.

22

9.

23

Starts businesses by actively managing their daily operations, including conducting inspections of

24

Narconon centers and creating, licensing, and approving their marketing materials.

Narconon International (NI) was doing business in the State of Nevada by and through

Fresh Start, NI, and Western are subsidiaries of the Association for Better Living and

Defendant ABLE is a corporation registered in the State of California with its headquarters

ABLE controls the time, manner, and method of Narconon Internationals and Fresh

25
2

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 3 of 16

10.

ABLE transacts business in the State of Nevada by and through its agents, Narconon

International and Narconon Fresh Start. ABLE may be served with process through its registered

agent, Timothy Bowles, One South Fair Oaks Avenue, Pasadena, California 91105.

11.

associate, or otherwise, of Defendant DOES 1-100, inclusive, and, therefore, sues these

Defendants by fictitious names. Plaintiff will seek leave of this Court to amend this Complaint

when the identities of these Defendants are ascertained.

Plaintiffs are unaware of the true names and capacities, whether individual, corporate,

II.

JURISDICTION AND VENUE

10

13.

This Court has subject jurisdiction pursuant to 28 U.S.C. 1332. The amount in

11

controversy exceeds $75,000.00, and there is complete diversity between the parties.

12

14.

13

of the events and omissions giving rise to this lawsuit occurred in this District, and the Court has

14

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

15

III.

16

FACTUAL ALLEGATIONS

17

15.

On or about January 8, 2015, Carla Savoie was searching the Internet for a drug

18

rehabilitation facility for her son, Joshua Savoie. Carla found a website that advertised assistance

19

to persons in finding an appropriate drug rehabilitation facility.

20

14.

21

named Tibor Palatinus the following day, January 9, 2015.

22

15.

23

traumatic events he had experienced.

24

16.

25

named Josh at Narconon Fresh Start, and a telephone number to call.

Carla and Paul called an 800 number listed on the website, and spoke to an individual

They spoke to Tibor at length about Joshuas background, drug usage, prescriptions, and

Tibor directed Plaintiffs to Narconon Fresh Start in Nevada. Tibor also gave them a contact

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 4 of 16

Over the next three days, Paul and Carla Savoie spoke on several occasions to Josh and

17.

another individual named Dan Carmichael as representatives of Narconon Fresh Start.

18.

professional trauma counseling and a medically supervised detox all at Fresh Starts Nevada

facility.

19.

high success rate.

20.

necessary information about their sons substance abuse for Fresh Start to render services.

Dan Carmichael and Josh represented to Plaintiffs that Narconon Fresh Start offered

Dan Carmichael and Josh further represented that Narconon Fresh Start had an extremely

Finally, Dan Carmichael and Josh represented to Plaintiffs that Plaintiffs had provided all

10

21.

Arrangements were then made for Plaintiffs son to enter the Narconon Fresh Start

11

program in Caliente, Nevada.

12

22.

13

Narconon Fresh Starts facility in Caliente, Nevada.

14

23.

15

transported to Fresh Starts facility in Caliente, Nevada.

16

24.

17

informing Plaintiffs that Fresh Start could not care for their son at their Nevada facility because his

18

withdrawal was too severe.

19

25.

20

to a facility in Huntington Beach, California.

21

26.

22

concerned about the Narconon program.

23

27.

24

Agreement).

25

28.

Paul and Carla Savoie paid Narconon Fresh Start $33,000.00 to for their sons treatment at

On or about January 13, 2015 Plaintiffs son arrived in Las Vegas, Nevada, to be

Plaintiffs received a phone call on January 14, 2015 from a Narconon representative

Instead, the Narconon representative informed Plaintiffs that their son had been transferred

After being told that their son had been sent to Huntington Beach, Paul and Carla became

Fresh Start sent Plaintiffs a Narconon Fresh Start Admission Agreement, (Admission

Plaintiffs never signed nor ratified the Admission Agreement.


4

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 5 of 16

29.

The Admission Agreement defines the treatment program Narconon Fresh Start offers as

follows: Fresh Start delivers a comprehensive drug and alcohol treatment program using the

Narconon program methodology. This methodology was written and developed by founder

William Benitez, and author L. Ron Hubbard.

30.

all religious doctrine and religious texts in the Scientology religion.

31.

about any connection between the Narconon Fresh Start program and L. Ron Hubbard or the

Scientology religion.

L. Ron Hubbard was the Founder of the Scientology religion. Hubbard is the sole source of

In their discussions with Dan Carmichael and Josh, Plaintiffs had never been informed

10

32.

Plaintiffs called Josh and Dan Carmichael at Narconon to discuss their concerns about their

11

sons treatment and whether the Narconon program had any connection Scientology.

12

33.

13

and Narconon.

14

34.

15

January 20, 2015 about 2:30 p.m. at Huntington Beach.

16

35.

Plaintiffs son never began the Narconon program.

17

36.

Plaintiffs requested a refund from Narconon Fresh Start.

18

37.

Narconon Fresh Start agreed to provide a partial refund but has to date not returned any

19

portion of Plaintiffs funds.

Plaintiffs spoke to Josh and he denied that there was any connection between Scientology

Plaintiffs did not believe Josh. Consequently, Plaintiff Paul Savoie picked up his son on

The Narconon Program

20

Fresh Start uses the the Narconon Treatment Program. This program consists of two

21

38.

22

components: (1) course materials consisting of eight books based on the works of L. Ron

23

Hubbard; and (2) a sauna and vitamin program known as the New Life Detoxification Program.

24

39.

Each patient in the Narconon program receives exactly the same written materials.

25
5

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 6 of 16

40.

The Narconon program has patients study introductory Scientology as a means of

treatment for substance abuse.

41.

philosophy such as the A-R-C triangle, the Eight Dynamics, the Conditions of Existence, Overts

and Withholds, word clearing, Suppressive Persons and Potential Trouble Sources,

Disconnection, Training Routines, and Objective Processing.

42.

The courses in the Narconon program are largely self-taught by the patients.

43.

According to manuals for administering the Narconon program, the Narconon program is

not to be mixed with any other treatment approaches.

Patients undergoing the Narconon program read about Scientology doctrines and

10

44.

Consequently, persons undergoing the Narconon treatment program are directed not to go

11

beyond the Narconon materials or deviate from the materials.

12

45.

The Narconon program contains no trauma counseling or counseling of any other type.

13

46.

In addition, Fresh Start has participants engage in a sauna program known as the New

14

Life Detoxification.

15

47.

16

Purification Rundown, or the Purif.

17

48.

18

the Scientology religions spiritual journey known as the Bridge to Total Freedom.

19

49.

20

remain the bodys fatty tissue long after use. The drug residue is released from the fatty tissue

21

from time-to-time into the bloodstream causing the individual to crave the drug, and, ultimately,

22

relapse. Fresh Start claims that the sauna program flushes these residual drug toxins out of the

23

addicts system thereby reducing the cravings the residue causes.

24

50.

25

entering the sauna each day. On entering the sauna, Narconon requires each student to ingest

The New Life Detoxification program is identical to the Scientology ritual known as the

The Purification Rundown is a required component of Scientology training and is part of

Fresh Starts rationale for the sauna program is that residue of many different types of drug

Under the New Life Detoxification program, students first exercise vigorously before

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 7 of 16

increasing doses of Niacin and a vitamin bomb. This includes dosages of Niacin well beyond

the recommended daily allowance.

51.

Rundown, are false and do not withstand scientific scrutiny.

52.

Narconon of Northern Georgia in a wrongful death suit filed against those entities, testified at a

deposition. Relevant portions of Dr. Casals deposition testimony are attached hereto as Exhibit

A. When asked under oath about the New Life Detoxification Program, he testified that there is no

scientific basis for the notion that sweating in a sauna detoxifies a persons body or treats

Fresh Starts claims about the benefits of its sauna program, i.e., Scientologys Purification

In a prior lawsuit, Dr. Louis A. Casal, an expert retained by Narconon International and

10

addiction:

11

Q.

12

Have you looked at the Narconon literature on what Narconon contends the

benefits from the sauna are?

13

A. [Dr. Casal] Yes, I have.

14

Q.

15

your body. True?

16

A.

True.

17

Q.

But theres no scientific basis that you can point to to support that contention, is

18

there, sir?

19

A.

Youre correct.

20

Q.

So when Narconon states that the sauna program detoxifies its students, youre not

21

And the sauna program, what Narconon contends is that in it in fact detoxifies

aware, as a medical doctor, of any scientific basis for that contention?


A.

22

I agree.

23

Exhibit A, Deposition of Dr. Louis Casal, 136:21 137:9.

24

53.

25

Fresh Start d/b/a Rainbow Canyon Retreat.

Narconon claims a success rate of 76% for all Narconon centers, including Narconon

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 8 of 16

54.

testified at his deposition that he was not convinced Narconons claimed success rate was true:
Q.

3
4

Dr. Casal, the medical expert retained by Narconon International in another lawsuit,

Okay. What are you relying on well, let me ask you this; do you believe that 76

percent success ratio is accurate?

A. [Dr. Casal]. Mr. Harris, Ill be honest with you, thats a big number.

Q.

Yeah, its its a real big number.

A.

Its a big number.

Q.

And its completely inconsistent

A.

I I hope its true, but, I mean, I would need some convincing.

10
11

Q.

Okay. Do you have any idea where Narconon is getting the numbers that its using?

12

A.

You know, in the interest of time I just didnt have enough time to delve deeper

13

into those studies, Mr. Harris. And I I would be happy to, but, no, I dont have a clear

14

understanding of where that 70 70-something number came from, no, sir.

15

Exhibit A, Deposition of Dr. Louis Casal, 124:21 125:5; 126:1 7.

16

55.

17

advised the Narconon Freedom Center not to say they have a 70% success rate when responding to

18

a Better Business Bureau complaint. Arcabascio advised against citing the success rate because

19

we do not have scientific evidence of it. Attached hereto as Exhibit B is a copy of Ms.

20

Arcabascios e-mail to the Narconon Freedom Center.

21

56.

22

Church of Scientology. For example, a Narconon document titled the Narconon Technical Line-

23

Up provides a flow chart of a patients experience into and through the Narconon program. The

24

document shows that when a patient finishes the Narconon program, the patient is to be route[d]

25

to the nearest Org for further services if the individual so desires. Org is Scientology jargon for

In addition, the Director of Legal Affairs for Narconon International, Claudia Arcabascio

Narconon documents indicate that the Narconon program is used to recruit patients into the

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 9 of 16

an individual church providing services for the Church of Scientology. A copy of the Narconon

Technical Line-Up is attached hereto as Exhibit C.

57.

to the Bridge. That is, Narconon considers its program to be an initial step into getting on

Scientologys Bridge to Total Freedom, the key spiritual journey that practitioners of the

Scientology religion undertake. See, e.g., Narconon News, 1974, Volume 6, Issue 3: Narconon Is

The Bridge to The Bridge, attached hereto as Exhibit D.

58.

that thanks Larry Trahant and The Narconon Fresh Start Team for introducing patients to L. Ron

10

Narconon and the Church of Scientology consider the Narconon program to be the Bridge

At Fresh Starts headquarters in Glendale, California, hangs a plaque received from ABLE

Hubbard and The Bridge. The writing on the plaque provides, in relevant part:

11

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
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.

12
13
14
15
16
17
18
19
20

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


59.

Scientologys own marketing documents show that the Narconon program is part of

Scientologys plan to clear civilization. (To go clear is the ultimate spiritual goal for a
Scientologist, achieved after one goes up the Bridge to Total Freedom.) The document attached
hereto as Exhibit F, shows a Church of Scientology, or an Org as its known, with an arrow
directed at the Narconon Jumping Man logo. The document reads:

21
22
23
24
25

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.
In other words, the Church of Scientology is supposed to direct Narconon to achieve Scientologys
spiritual goal of clearing civilization.

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 10 of 16


60.

Defendant ABLE owns the trademarks for Narconon, including all rights to the Narconon

1
2

Jumping Man logo.

61.

document attached hereto as Exhibit F.

Defendant ABLE gave permission for the Narconon Jumping Man logo to be used in the

5
6
7
8
9
10
11
12
13

62.

Fresh Start is using the Narconon program to introduce Scientology and L. Ron Hubbards

technology to unwitting patients seeking drug rehabilitation. This is exactly as the Church of
Scientology directed as part of its Social Coordination Strategy. Scientology explicitly outlined
this strategy in an urgent Executive Directive from the Authorization, Verification, and Correction
Department of its Religious Technology Center. The Executive Directive outlining the Social
Coordination Strategy is attached hereto as Exhibit G (hereafter the SOCO Directive).

61.

The SOCO Directive instructed all SOCO GROUPS, which includes Narconon, as

follows:

14

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).

15
16
17
18

The SOCO Directive expressly directed using front groups to introduce L. Ron Hubbards

19

technology, i.e., Scientology to society.

20

62.

SOCO, or the Social Coordination Bureau of the Church of Scientology, is the predecessor

21

in interest to Defendant ABLE.


22
23

///

24

///
25
10

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 11 of 16


NI, Western, and ABLE Control Narconon Fresh Start
1
2

63.

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:


4

64.

Defendant Narconon Fresh Start has all appearances of being a corporate sham illusion and

mere instrumentality of Defendants NI, ABLE, and Western


6

65.

ABLE, NI and Western heavily influence Narconon Fresh Start and govern and control

nearly every aspect of Narconon Fresh Starts business activities.


8

66.

NI publishes manuals that individual Narconon Centers such as Fresh Start d/b/a Sunshine

Summit Lodge are required to follow in operating the individual Narconon center. Two of these
10

manuals are entitled Opening A Successful Narconon Center and Running An Effective
11

Narconon Center.
12

67.

These manuals indicate that an individual Narconon center can do very little without the

13

approval of NI, Western, and ABLE.


14

68.

Narconon Fresh Start cannot transfer, demote, or dismiss a permanent staff member

15

without the approval of NI.


16

69.

NI, Western, and ABLE have ultimate authority over the hiring of any Fresh Start staff

17

member. If a Narconon Fresh Start staff member does not meet the qualifications of a staff
18
19
20

member, the staff member may petition the Senior Director of Administration at NI to remain on
staff.

21

70.

22

materials that make it hard or impossible for her to do her job, she may file a Job Endangerment

23

Chit with the Ethics Department at NI. NI and Western then investigate and work to resolve the

24

staff members issue.

If a staff member at Narconon Fresh Start believes she has been given orders or denied

25
11

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 12 of 16


72.

The operations manuals require staff members at Narconon Fresh Start to report

1
2
3
4
5

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.
73.

Western receives ten percent of the weekly gross income from Narconon Fresh Start.

74.

NI requires Narconon Fresh Start to send it detailed weekly reports containing statistics of

more than 40 different metrics. NI and Western review these weekly reports and order changes at
7

Narconon Fresh Start based on increases or decreases in the statistics in the reports.
8

75.

NI, Western, and ABLE require that Narconon Fresh Start receive approval on all

promotional materials before Fresh Start disseminates them. Further, Fresh Start must obtain
10

approval as to its Internet websites from NI, Western, and ABLE before the sites go live.
11

76.

NI, Western and ABLE also assist in creating Narconon Fresh Starts advertising

12

materials. NI, Western and ABLE dictate the contents of those advertising materials.
13

Narconon International and ABLE monitor the delivery of the treatment that Fresh Start
14

provides. The written materials in the Narconon program consist of the writings and works of L.
15

Ron Hubbard. Narconon and Scientology refer to these materials as technology or tech.
16

77.

NI requires that Narconon Fresh Start maintain a building account fund in which weekly

17

monies from the gross income are used to purchase new premises and also as a cushion to salvage
18

the organization in dire circumstances. The building fund is under the control of NI.
19

78.

NI, Western and ABLE conduct tech inspections at Narconon Fresh Start. These

20

inspections entail NI, Western, and ABLE monitoring and correcting the manner in which
21

Narconon Fresh Start delivers the Narconon treatment program to patients at Fresh Start. NI,
22

Western, and ABLE instruct staff at Fresh Start as to the exact manner in which they are to
23

perform their services and deliver the Narconon treatment program.


24
25
12

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 13 of 16

79.

NI and ABLE also publish all training materials for Narconon Fresh Start. This includes

seven different training materials on subjects ranging from the Narconon sauna program to

overseeing to delivering the Narconon treatment program.

80.

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.

81.

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

10

82.

NI, Western, and ABLE are intimately involved in the day-to-day operations of Narconon

11

Fresh Start. NI, Western, and ABLE have the final authority over all decisions at Narconon Fresh

12

Start relating to hiring and firing, delivery of services, finances, advertising, training, and general

13

operations.

14

83.

NI, Western, and ABLE all are principals served by their agent, Fresh Start.

15

FIRST CLAIM FOR RELIEF

16

UNJUST ENRICHMENT

17

84.

Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation

18

set forth in the preceding paragraphs and further allege as follows:

19

85.

20

drug rehabilitation services that Defendants promised to provide.

21

86.

22

services Defendants promised to provide, including without limitation, medically supervised

23

detox, trauma counseling, and drug rehabilitation.

24

87.

25

they obtained from Plaintiffs.

Defendants received benefits from Plaintiffs, including without limitation, $33,000.00 for

Defendants did not provide, nor were they equipped to provide to Plaintiffs son the

Under the circumstances, it would be unjust to allow the Defendants to retain the benefits

13

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 14 of 16

SECOND CLAIM FOR RELIEF

FRAUD

88.

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:

89.

represented to Plaintiffs that Fresh Start (i) would provide Plaintiffs son medically supervised

detox at their Nevada facility; and (ii) that Fresh Starts treatment program provided trauma

counseling.

90.

Defendants, through Narconon representatives Josh and Dan Carmichael, falsely

Dan Carmichael and Josh, Narconon representatives, made these statements to Plaintiffs on

10

or about January 10-13, 2015, to induce Plaintiffs to admit their son to Narconon.

11

91.

12

Fresh Start $33,000.00, nor would they have admitted their son to Fresh Start for treatment.

13

92.

14

damages.

Had Plaintiffs known these statements to be false, they would not have paid Narconon

As a proximate result of Defendants fraudulent conduct, Plaintiffs have suffered pecuniary

15

THIRD CLAIM FOR RELIEF

16

NEGLIGENT MISREPRESENTATION

17

93.

Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set

18

forth in the preceding paragraphs and further alleges as follows:

19

94.

20

and Dan Carmichael, falsely represented to Plaintiffs that Fresh Start (i) would provide Plaintiffs

21

son medically supervised detox at their Nevada facility; and (ii) that Fresh Starts treatment

22

program provided trauma counseling.

23

95.

Defendants made these representations of fact without using reasonable care.

24

96.

Defendants knew that Plaintiffs would rely on these representations of fact.

On or about January 10 13, 2015, Defendants, through Narconon representatives Josh

25
14

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 15 of 16

97.

Defendants made these statements to guide Plaintiffs in their business transaction with

Defendants.

98.

Plaintiffs suffered damages in excess of $75,000.00.

Plaintiffs relied on these false representations of fact to their detriment and, as a result,

FOURTH CLAIM FOR RELIEF

FRAUD CLAIMS PURSUANT TO NRS 41.600

99.

Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set

forth in the preceding paragraphs and further allege as follows:

100.

By reason of Defendants actions complained of herein, Plaintiffs are victims of consumer

10

fraud.

11

101.

12

598.0915 to 598.0925, inclusive.

13

102.

14

respect to Plaintiffs: (i) advertising substance abuse treatment with the intent not to sell them as

15

advertised by providing Scientology instead; (ii) using bait and switch advertising whereby

16

Defendants advertise extensive substance abuse counseling and treatment and then deliver a

17

treatment program wherein the patient receives Scientology teachings and rituals; and (iii)

18

failing to disclose material facts to Plaintiffs about the services Defendants were selling including,

19

but not limited to, the fact that the Narconon treatment program consisted of Scientology doctrines

20

and practices.

21

103.

22

as a result, have suffered substantial pecuniary damages and other injuries.

23

104.

Defendants have engaged in numerous deceptive trade practices as defined in NRS

The following is a list of the deceptive trade practices Defendants have engaged in with

Plaintiffs have been the victims of Defendants deceptive trade practices listed above and,

Defendants deceptive trade practices are likely to continue without court intervention.

24
25
15

Case 2:15-cv-00872-JCM-VCF Document 1 Filed 05/08/15 Page 16 of 16

Plaintiffs are entitled to all available relief under NRS 41.600 including Plaintiffs

105.

attorneys fees and costs of this action, Plaintiffs damages, and an injunction restraining

Defendants from further engaging in the deceptive trade practices complained of herein.
DEMAND FOR JURY TRIAL

4
5

Plaintiffs demand a jury trial on all issues triable.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for the following relief:

8
9

A. Judgment in favor of Plaintiffs and against Defendants for damages in such amounts as
may be proven at trial;

10

B. Compensation for special, general, and treble damages;

11

C. Reasonable attorneys fees and costs of suit;

12

D. Interest at the statutory rate;

13

E. Punitive or exemplary damages against Defendant;

14

F. All further relief, both legal and equitable, that the Court deems just and proper.

15

DATED this May 8, 2015.


Respectfully submitted,

16
17

By:/s/ Ryan A. Hamilton


18

22

RYAN A. HAMILTON, ESQ.


NV BAR NO. 11587
HAMILTON LAW
5125 S. Durango Dr., Ste. C
Las Vegas, NV 89113
(702) 818-1818
(702) 974-1139
ryan@hamiltonlawlasvegas.com

23

Attorney for Plaintiffs

19
20
21

24
25
16