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Filing # 95934563 E-Filed 09/18/2019 04:50:11 PM

IN THE CIRCUIT COURT FOR THE 11TH


JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA

CIVIL DIVISION

Case No.:

JANE DOE,

Plaintiff,

v.

CHURCH OF SCIENTOLOGY FLAG


SERVICE ORGANIZATION, INC., a Florida
corporation; CLEARWATER ACADEMY,
INC., a Florida corporation; THE CHURCH
OF SCIENTOLOGY INTERNATIONAL, a
California corporation; RELIGIOUS
TECHNOLOGY CENTER, a California
corporation; and DAVID MISCAVIGE, a
California resident;

Defendants.
_____________________________________/

COMPLAINT FOR DAMAGES

INTRODUCTION

This case is brought against the Defendant Organizations of Scientology; its leader, David

Miscavige; and Clearwater Academy, a Scientology school, for the continued sexual abuse that

Jane Doe suffered at the hands of Defendants’ employees, members, agents, and/or

representatives, and, thereafter, because the Defendants conspired to and did cover up those

crimes. When Jane Doe came forward to make Defendants’ crimes known to the public, the

Defendants continued their conspiracy against Plaintiff and systematically stalked, harassed,

invaded her privacy, and intentionally caused her emotional distress to silence and intimidate her.
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 a

result of Defendants’ intentional acts, described below. Information which could identify Jane

Doe is not contained herein. Plaintiff may be contacted through her counsel. There exists good

cause 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. She

has 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 identity of Plaintiff to all

Defendants. As such, Defendants suffer no prejudice as a result of concealing her identity in the

Complaint.

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, Florida

33756, 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 Florida

corporation with its principal place of business in Clearwater, Florida.

5. At all times material, Jim Zwers, 801 Drew Street, Clearwater, Florida 33755, is

and was the Registered Agent for Clearwater Academy and may accept service of process under

Florida Statutes section 48.091.

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6. Defendant The Church of Scientology International (“CSI”) is a California

corporation with its principal place of business in California.

7. Defendant Religious Technology Center (“RTC”) is a California corporation with

its 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, they reside in Miami-Dade County, Florida; engage in substantial and not isolated business

activity 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 in

this State.

11. Venue is proper in Miami-Dade County, Florida pursuant to Florida Statutes

section 47.051, as Defendants CSI and RTC, who do business in this state, reside and/or have

agents and representatives in Miami-Dade County, Florida.

FACTUAL HISTORY

12. The Institutional Defendants, along with a network of organizations that operate

under 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 “The

Church of Scientology.” Defendant Miscavige directs, operates, supervises, and/or controls the

Institutional Defendants, including their suborganizations or divisions, and Clearwater Academy.

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14. The Institutional Defendants own and/or operate Defendant Clearwater Academy.

15. The senior hierarchy of Scientology organizations, including, but not limited to the

RTC, CSI, and Flag Service are staffed and operated by an organization known as the Sea

Organization (“Sea Org”). The Sea Org is comprised of Scientology’s most dedicated members.

16. The RTC is tasked with ensuring that all Scientology organizations and members

comply with Scientology policies.

Reporting Crime is Forbidden

17. Whether discovered during auditing, described in detail below, or otherwise,

Defendants forbid members from contacting police to report a crime committed by any member.

The Institutional Defendants instruct their employees, members, and agents that reporting such

instances to law enforcement is considered a “high crime” and subjects the employee, member,

and/or agent to punishment. This policy was also carried out by Clearwater Academy at the

direction of the Institutional Defendants.

18. The Defendants instruct their members and agents that:

Police and courts offer an open-armed opportunity to the vicious and


corrupt to establish themselves in a position of safety while
satisfying their strange appetites of perverted viciousness toward
their fellow man. . . . Justice systems thereby become a sort of cancer
which erode every splendid ambition and achievement of the decent
citizen. . . . “Justice” apparently cannot be trusted in the hands of
Man. . . . Who is Public Enemy #1 today? The FBI! Its obvious
target is every opinion leader and public-spirited group in America!1

19. The Institutional Defendants instruct their employees, members, and agents that the

only answer to a crime being committed by its employees, members, and agents, including rape or

other sexual abuse, is found in the practices directed by the Defendants, not law enforcement or

5
L. Ron Hubbard, INTRODUCTION TO SCIENTOLOGY ETHICS (1972).

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the court system. Victims (and all others) are expressly prohibited from contacting law

enforcement.

20. To prevent employees, members, and agents from contacting authorities when any

crime is revealed, witnessed, or suspected, the Institutional Defendants and Defendant Miscavige

require the phones within certain facilities to be incapable of dialing 911.

The Defendants Punish Those Who Report Crimes

21. Defendants do not treat victims of sexual abuse as victims at all. Instead, one who

suffers sexual abuse (whether an adult or a child) is assumed to have done something to incite or

invite such abuse.

22. Historically, when a member has complained of suffering sexual abuse, this

disclosure has resulted in the member being forced to confront or apologize to his or her abuser.

23. There is a department within CSI known as the Office of Special Affairs (“OSA”).

OSA is the legal, public relations, and intelligence network of CSI. One or more network

representatives from OSA are employed at every Scientology organization across the world.

24. OSA and its operations were and are directed by Defendant Miscavige.

25. The Defendants, through OSA, utilize what Scientology calls “Fair Game” tactics

to attack, harass, embarrass, humiliate, destroy, and/or injure individuals who Defendants declare

to be a “suppressive person” or “SP.”

26. Defendants declare anyone who flees or speaks out against Scientology a

suppressive person and direct employees, members, and agents to subject them to such Fair

Gaming as described more fully below.

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Sea Org

27. One of the Institutional Defendants’ suborganizations is the Sea Organization, or

“Sea Org.”

28. Unbeknownst to members before contracting to work for the Sea Org, once

contracted, members are forced into difficult and illegal labor conditions, constantly under a threat

of punishment and paid only a small amount of money that makes it difficult for them to break

free. Sea Org members are forced to work an average of 100 hours per week, without lawfully

required breaks, and are given only a small weekly allowance instead of fair wages.

Human Trafficking within the Sea Org

29. The Sea Org, in large part, functions by way of human trafficking, including the

trafficking of children.

30. Defendants engage in the forced labor of adults and children in the Sea Org.

Defendants have made billions off the backs of men, women, and children who are trafficked and

forced to work 100 hour weeks for far below the minimum wage with little to no free time or

vacation under the threat of severe punishment for failure to perform their work duties.

31. Defendants have long engaged in a practice of separating children from their

parents, including, but not limited to, Sea Org members. In doing so, Defendants assume the

responsibility of in loco parentis.

32. Many times, children Sea Org members are sent to and/or transferred between the

Defendants’ facilities in Florida, California, and elsewhere under the guise of false promises where

they are forced to live without much, if any, adult and/or adequate supervision and required to

work long days and weeks without much, if any, time off and for little money. Child Sea Org

members are neglected and abused, physically and mentally, and are routinely placed in isolation.

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33. Child Sea Org members often have their food rationed and/or limited.

34. Child Sea Org members often must perform jobs that expose them to a high risk of

danger such as removal of asbestos, welding, construction/working on scaffolding, chemical

exposure, etc. and are often required to do so without necessary safety equipment.

35. Child Sea Org Members often have restricted and limited sleep due to the hours

and duties they are required to fulfill.

36. Child Sea Org members are unable to attend school and receive adequate education

due to the work requirements of the Sea Org and the threat of punishment for failure to perform

adequately.

37. Child Sea Org members are coached to lie and or/conceal information, including

information concerning the abuses within Scientology, to the public, authorities, family, and non-

Scientologists.

38. All of the aforementioned abuses above occur to child Sea Org members into

adulthood, as long as they remain a Sea Org member.

39. Should a Sea Org member flee to escape these abuses, whether a child or adult,

Defendants require any member of Defendants’ organization who is related to, friends with, or an

associate of someone who flees or speaks out about the abuses in Scientology to immediately

disassociate from that person. This policy is known as “disconnection.”

40. In other words, once an individual Sea Org member defects or flees Defendants’

grip or speaks out about the abuses within Scientology, that person’s family members and friends

who remain in Scientology must completely and unwaveringly disassociate from them. This means

separation of parents from children, relatives from relatives, friends from friends, and divorce in

the instance of spouses.

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41. To summarize, personal freedoms are restricted, families are separated, and severe

punishments are utilized to maintain complete control over the forced workers, including children,

in the Sea Org. The Defendants control and direct Sea Org members (as well as Scientology

members as a whole) through brain washing and the destruction of their independence and self-

control. Sea Org members, including children, are isolated from the outside world, their access

to information is heavily monitored, controlled, and limited, and Sea Org members are subjected

to physical, verbal, psychological, emotional, and/or sexual abuse and/or assault.

The Practice of Auditing

42. Members, including children, are required to be “audited” repeatedly and

continuously while a member of Scientology. Auditing sessions may occur daily and involve

several hours of being forced to reveal explicit, personal details regarding daily thoughts, activities,

etc.

43. During an “auditing session,” a member meets with an “auditor,” who is generally

a higher-ranking Scientologist and often a Sea Org member. The “auditor” has the member hold

two metal rods commonly referred to as “cans” of an “electropsychometer” or “e-meter.” An e-

meter, is designed to “measure[] the mental state or change of state of a person and thus is of

benefit to the auditor . . . [to] locate areas to be handled.”2 As Hubbard said and Defendants

maintain, “an e-meter is better known as a ‘lie detector’ and is used to ascertain truth of background

and conduct.”3 During these “auditing” sessions the “auditor” takes copious notes on what the

2
CHURCH OF SCIENTOLOGY INT’L, http://www.whatisscientology.org/html/Part14/Chp50/pg1020-
a.html (last visited Aug. 12, 2019).
3
Hubbard Commc’ns Office Bulletin from L. Ron Hubbard, Scientology Founder, regarding
Security Check[s] (Feb. 3, 1960).

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individual reports. These notes are then placed in a folder and maintained by Scientology

permanently.

44. Defendants require all members to undergo this extensive and expensive process

regardless of their age. This includes children of any age.

Fair Game

45. The Defendants utilize what Scientology calls “Fair Game” tactics to attack, harass,

embarrass, humiliate, destroy, and/or injure individuals who Defendants declare to be a

“suppressive person.”

46. The Defendants declare anyone who flees or speaks out against Scientology a

suppressive person and directs members and agents to subject them to such Fair Gaming. Members

of Scientology are directed, by the Defendants, to, among other methods, deprive that individual

of property, injure that person by any means, and/or destroy that individual. It is specifically

directed by the Defendants that if a member of Scientology does any of the above to a “suppressive

person” and/or enemy, they will not be disciplined in any fashion.

47. Many individuals who wish to leave the control, membership, or employ of the

Defendants are forced to flee or attempt escape as leaving of their own free will is often not an

option, as was the case of Plaintiff herein.

48. For children who grow up in Scientology as well as child Sea Org members who

remain in Scientology into adulthood, this threat of being “destroyed” by Defendants’ Fair Game

tactics, along with knowing your family and friends will cease all contact with you should you

leave, having little to no education, money, tangible goods, etc. traps them into ever being able to

leave or speak up/report abuse within the Defendants’ organization.

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49. In fact, in a further effort to prevent members, including Sea Org members, from

leaving or speaking out about the abuses in Scientology, Defendants, through their employees and

agents or otherwise, upon becoming aware of a Sea Org members’ desire to flee or leave, require

members to submit to videotaped statements wherein the member is forced to describe their time

in Scientology and the Sea Org as nothing but delightful. Defendants also will force individual

members to sign waivers agreeing not to sue the Defendants for anything.

50. Defendants will also require family members (who remain in Scientology) of

individuals who flee and/or speak out against the abuses in Scientology to submit to videotaped

statements wherein the sole purpose of the video is to speak badly and defame the individual who

has fled or spoken out.

51. Per Defendants’ directives and the Fair Game policy, anyone who flees

Scientology, any critic of Scientology, or person who reports or speaks out about the abuses

occurring within Scientology, must be silenced by whatever means necessary. Defendants instruct

members to damage the person’s professional reputation, file frivolous lawsuits, and harass and

surveil “the enemy.”

52. A person who is declared an enemy of Scientology is Fair Game for relentless and

cruel behavior. A person who is Fair Game “[m]ay be deprived of property or injured by any means

by any Scientologist without any discipline of the Scientologist. May be tricked, sued or lied to or

destroyed.”4

53. Defendants instruct their agents, employees, members, and representatives, that

pursuant to Scientology’s creator, Ron L. Hubbard’s, mandates, they are to disseminate

information that will damage the individual’s professional and private reputation regardless of the

4
Allard v. Church of Scientology, 58 Cal. App. 3d 439 n.1 (Ct. App. 1976).

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truth of the information disseminated. Defendants have created dozens of websites dedicated to

defaming, intimidating, and harassing those they determine are enemies of Scientology.

Defendants’ policies and procedures encourage and/or instruct followers to “ruin [the individual]

utterly.”5

54. Defendants have solicited estranged family members of alleged “suppressive

persons” to publicly insult and harass them.

55. Courts have repeatedly acknowledged the existence of this policy. The Defendants

have a “history of seeking retribution against [their] perceived enemies.”6

Scientology’s Abuse of Plaintiff Jane Doe

56. Jane Doe was born into Scientology on September 19, 1994.

57. Jane Doe attended Clearwater Academy.

58. Clearwater Academy is a Scientologist school serving Pre-K to 12th grade.

59. During her years there in grades K1 and part of K2, Jane Doe was repeatedly

sexually assaulted by an employee of Clearwater Academy.

60. This abuse included, but was not limited to:

a. Multiple instances when the employee forced Jane Doe and other young
girls to perform sexual acts on each other;

b. Multiple instances when the employee masturbated in the presence of Jane


Doe and ejaculated on Jane Doe; and

5
L. Ron Hubbard, A Manual on the Dissemination of Material, THE MAGAZINE OF DIANETICS AND
SCIENTOLOGY, Mar. 1955, at 157.
6
See also Wollersheim v. Church of Scientology, 212 Cal. App. 3d 872, 880, (Ct. App. 1989), cert.
granted, judgment vacated sub nom. Church of Scientology of California v. Wollersheim, 499 U.S.
914 (1991) (“Scientology is a hierarchical organization which exhibits near paranoid attitudes
toward certain institutions and individuals—in particular, the government, mental health
professions, disaffected members and others who criticize the organization or its leadership.
Evidence also was introduced detailing Scientology's retribution policy, sometimes called “fair
game.”).

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c. At least once instance when the employee forced his penis into Jane Doe’s
mouth.

61. Jane Doe reported this abuse to other employees of Clearwater Academy on

multiple occasions and no action was taken to remove the employee from the school.

62. Even after Clearwater Academy was made aware of the abuse, the abuse continued.

63. Other employees of Clearwater Academy would facilitate the abuse by calling Jane

Doe from her classroom and sending her to be alone with her abuser.

64. After this time, when Jane Doe was only eleven years old, she was sent by

Scientology to live in Caracas, Venezuela, without her parents.

65. During this time, when Jane Doe was twelve years old, Jane Doe was violently

sexually assaulted on the premises of the Caracas Org by the adult son of wealthy, high-ranking

scientologists.

66. Jane Doe immediately reported this incident to her auditor. Jane Doe’s auditor got

extremely angry at Jane Doe, instead of her attacker, and subjected her to punishment as a result

of the report.

67. Specifically, the Institutional Defendants “sentenced” Jane Doe to three months of

hard, physical labor. Other members were ordered not to speak to Jane Doe during this time. The

Institutional Defendants issued a “non-enturbulation” order against Jane Doe, which is a form of

punishment warning Jane Doe that she was at risk of losing good standing with Scientology

because of her actions of “bringing-in” (or causing through her own actions) the sexual assault.

68. After Jane Doe completed her “sentence,” she was sent back to Clearwater,

Florida, where she then became a member of the Sea Org at the age of fourteen. During her time

as a member of the Sea Org, Jane Doe was subjected to long hours of difficult physical labor for

little to no wages.

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69. For a brief time, Jane Doe was out of the Sea Org, before she was recruited back in

by the Institutional Defendants’ agent and employee, Senior Persof of the Hubbard

Communication Office, Katherine Richie.

70. Katherine Richie arranged to become Jane Doe’s guardian with the approval of the

Institutional Defendants. Once Jane Doe was under the control of Katherine Richie, Katherine

Richie groomed Jane Doe to enter into a sexual relationship with her and Richie began sexually

abusing Jane Doe, who was still a minor.

71. The Institutional Defendants’ agents and employees knew or should have known

that Katherine Richie was abusing Jane Doe and should have prevented such abuses from

occurring, but they did not.

72. Eventually, in 2018, Jane Doe escaped from Scientology. After that time, the

Institutional Defendants have launched a fair-gaming campaign against Jane Doe. The

Institutional Defendants’ fair game attacks include, but are not limited to, tampering with Jane

Doe’s vehicle, including cutting her brake lines; vandalizing her property; following her;

surveilling her; and conducting hundreds of spam/crank phone calls to Jane Doe’s phone.

73. At all times material, Defendants controlled and/or had the right to control the

physical conduct of their employees, agents, members, and/or representatives.

74. Any statutes of limitations relating to any cause of action in this complaint were

suspended until Plaintiff’s escape from Scientology, and for a reasonable time period after, because

she could not have reasonably discovered the wrongfulness of Defendants’ conduct or any of her

causes of action, legal rights, or pursue any remedy due to the psychological trauma and abuse,

linguistic and cultural isolation, inability to access services, physical abuse, debilitating fear from

Defendants’ threats and harassment, and other barriers caused by Defendants’ unlawful conduct.

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COUNT I
SEXUAL BATTERY AGAINST
CLEARWATER ACADEMY INTERNATIONAL

75. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

76. Defendant Clearwater Academy’s employee, agent, member, and/or representative

committed a sexual battery upon Plaintiff when he intentionally penetrated Plaintiff’s mouth with

his penis against Plaintiff’s will and without her consent.

77. Defendant Clearwater Academy’s employee, agent, member, and/or representative

sexually abused Plaintiff on school property.

78. Defendant Clearwater Academy’s employee, agent, member, and/or representative

used his position of authority with Clearwater Academy to manipulate and intimidate Plaintiff, a

minor at the time of the sexual battery.

79. Defendant Clearwater Academy’s employee, agent, member, and/or representative

had access to and the opportunity to abuse Plaintiff because of his official position and duties with

Clearwater Academy.

80. Plaintiff reported the sexual battery to other Clearwater Academy employees on

multiple occasions, but no action was taken to remove the employee and the sexual batteries

committed by Defendant Clearwater Academy’s employee, agent, member, and/or representative

upon Plaintiff continued.

81. Defendant Clearwater Academy is vicariously liable for the sexual battery

committed by its employee, agent, member, and/or representative because the employee, agent,

member, and/or representative committed the sexual battery in the course and scope of his

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employment and for the benefit and interest of Defendant Clearwater Academy and in keeping

with Clearwater Academy’s teachings and instructions.

82. Defendant Clearwater Academy is vicariously liable for the sexual battery

committed by its employee, agent, member, and/or representative because the employee, agent,

member, and/or representative was assisted in accomplishing the sexual battery upon Plaintiff by

and through the existence of his employee/employer relationship with Defendant Clearwater

Academy.

83. As a direct and proximate result of Defendant Clearwater Academy’s employee,

agent, member, and/or representative’s sexual battery of Plaintiff and for which Clearwater

Academy is vicariously liable, Plaintiff suffered serious and permanent injuries.

84. Defendants are therefore liable to Plaintiff for all damages to which Plaintiff may

be entitled under applicable law, which include, but are not limited to, bodily injury and resulting

pain and suffering, disability, mental anguish, loss of capacity for the enjoyment of life, medical

treatment, medical expenses, and loss of income.

85. Plaintiff reserves the right, upon the proper showing of record evidence, to amend

the Complaint to seek punitive damages resulting from Defendant Clearwater Academy’s

employee, agent, member, and/or representative’s intentional, wanton, and willful acts, and gross

negligence, for which Clearwater Academy is vicariously liable.

WHEREFORE, Plaintiff demands judgment for damages against Defendant Clearwater

Academy, together with the costs of this action and such further relief as the Court deems

appropriate. Plaintiff further demands trial by jury of all issues triable as of right.

COUNT II
SEXUAL BATTERY AGAINST FLAG SERVICE AND/OR
CHURCH OF SCIENTOLOGY INTERNATIONAL

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86. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

87. Defendants Flag Service and/or CSI’s employee, agent, member, and/or

representative, Katherine Richie, committed a sexual battery upon Plaintiff when she intentionally

began sexually abusing and having a sexual relationship with Plaintiff while she was a minor.

Specifically, Plaintiff was 14–15 at the time of the sexual relationship and abuse and Katherine

Richie was older than 24 years of age.

88. As a minor at the time of the relationship and abuse, Plaintiff did not anticipate or

understand the consequences of her actions and could not consent to the sexual abuse and/or

relationship.

89. Defendants Flag Service and/or CSI’s employee, agent, member, and/or

representative, Katherine Richie, committed the sexual abuse on property controlled, managed,

and operated by Defendant CSI.

90. Defendants Flag Service and/or CSI’s employee, agent, member, and/or

representative, Katherine Richie, used her position of authority with Flag Service and/or CSI to

manipulate and intimidate Plaintiff, a minor at the time of the sexual battery.

91. Defendants Flag Service and/or CSI’s employee, agent, member, and/or

representative, Katherine Richie, had access to and the opportunity to abuse Plaintiff because of

her official position and duties with Flag Service and/or CSI.

92. Defendants Flag Service and/or CSI knew or should have known that Katherine

Richie was sexually abusing Plaintiff and should have prevented such abuses from occurring, but

did not.

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93. Defendants Flag Service and/or CSI are vicariously liable for the sexual battery

committed by their employee, agent, member, and/or representative, Katherine Richie, because

she committed the sexual battery in the course and scope of her employment and for the benefit

and interest of Defendants Flag Service and CSI and in keeping with Flag Service and CSI’s

teachings and instructions.

94. Defendants Flag Service and/or CSI are vicariously liable for the sexual battery

committed by their employee, agent, member, and/or representative, Katherine Richie, because

she was assisted in accomplishing the sexual battery upon Plaintiff by and through the existence

of her employee/employer relationship with Defendants Flag Service and/or CSI.

95. As a direct and proximate result of Defendants Flag Service and/or CSI’s employee,

agent, member, and/or representative, Katherine Richie’s, sexual battery of Plaintiff and for which

Flag Service and/or CSI are vicariously liable, Plaintiff suffered serious and permanent injuries.

96. Defendants Flag Service and/or CSI are therefore liable to Plaintiff for all damages

to which Plaintiff may be entitled under applicable law, which include, but are not limited to,

bodily injury and resulting pain and suffering, disability, mental anguish, loss of capacity for the

enjoyment of life, medical treatment, medical expenses, and loss of income.

97. Plaintiff reserves the right, upon the proper showing of record evidence, to amend

the Complaint to seek punitive damages resulting from Defendants Flag Service and/or CSI’s

employee, agent, member, and/or representative’s intentional, wanton, and willful acts, and gross

negligence, for which Clearwater Academy is vicariously liable.

WHEREFORE, Plaintiff demands judgment for damages against Defendants Flag Service

and CSI, together with the costs of this action and such further relief as the Court deems

appropriate. Plaintiff further demands trial by jury of all issues triable as of right.

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COUNT III
BATTERY AGAINST CLEARWATER
ACADEMY INTERNATIONAL

98. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

99. Defendant Clearwater Academy’s employee, agent, member, and/or representative

committed a battery upon Plaintiff when he intentionally masturbated in her presence and

ejaculated on her, against Plaintiff’s will and without her consent.

100. Defendant Clearwater Academy’s employee, agent, member, and/or representative

committed this battery upon Plaintiff on school property.

101. Defendant Clearwater Academy’s employee, agent, member, and/or representative

used his position of authority with Clearwater Academy to manipulate and intimidate Plaintiff, a

minor, at the time of the battery.

102. Defendant Clearwater Academy’s employee, agent, member, and/or representative

had access to and the opportunity to abuse Plaintiff because of his official position and duties with

Clearwater Academy.

103. Plaintiff reported the battery to other Clearwater Academy employees on multiple

occasions, but no action was taken to remove the employee and the batteries committed by

Defendant Clearwater Academy’s employee, agent, member, and/or representative upon Plaintiff

continued.

104. Defendant Clearwater Academy is vicariously liable for the batteries committed by

its employee, agent, member, and/or representative because the employee, agent, member, and/or

representative committed the batteries in the course and scope of his employment and for the

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benefit and interest of Defendant Clearwater Academy and in keeping with Clearwater Academy’s

teachings and instructions.

105. Defendant Clearwater Academy is vicariously liable for the batteries committed by

its employee, agent, member, and/or representative because the employee, agent, member, and/or

representative was assisted in accomplishing the batteries upon Plaintiff by and through the

existence of his employee/employer relationship with Defendant Clearwater Academy.

106. As a direct and proximate result of Defendant Clearwater Academy’s employee,

agent, member, and/or representative’s batteries of Plaintiff and for which Clearwater Academy is

vicariously liable, Plaintiff suffered serious and permanent injuries.

107. Defendants are therefore liable to Plaintiff for all damages to which Plaintiff may

be entitled under applicable law, which include, but are not limited to, bodily injury and resulting

pain and suffering, disability, mental anguish, loss of capacity for the enjoyment of life, medical

treatment, medical expenses, and loss of income.

108. Plaintiff reserves the right, upon the proper showing of record evidence, to amend

the Complaint to seek punitive damages resulting from Defendant Clearwater Academy’s

employee, agent, member, and/or representative’s intentional, wanton, and willful acts, and gross

negligence, for which Clearwater Academy is vicariously liable.

WHEREFORE, Plaintiff demands judgment for damages against Defendant Clearwater

Academy, together with the costs of this action and such further relief as the Court deems

appropriate. Plaintiff further demands trial by jury of all issues triable as of right.

COUNT IV
VIOLATION OF FLORIDA STATUTES SECTION 800.101
AGAINST CLEARWATER ACADEMY INTERNATIONAL

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109. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

110. At the time that Defendant Clearwater Academy’s employee, agent, member,

and/or representative committed the sexual batteries upon Plaintiff, he was an authority figure who

was employed by, volunteering at, or under contract with Clearwater Academy.

111. At the time that Defendant Clearwater Academy’s employee, agent, member,

and/or representative committed the sexual batteries upon Plaintiff, Plaintiff was a student at

Clearwater Academy.

112. Defendant Clearwater Academy’s employee, agent, member, and/or representative

violated Florida Statutes section 800.101 when he engaged in sexual and/or lewd conduct with

Plaintiff, as described above.

113. Florida Statutes section 800.101 establishes a duty to protect students in schools,

including private schools, from authority figures at those schools who engage in or solicit sexual

and/or lewd conduct with a student.

114. Plaintiff belongs to the class of individuals that Florida Statutes section 800.101

was intended to protect.

115. Plaintiff suffered injury of the type that Florida Statutes section 800.101 was

designed to prevent, to wit she was a student subjected to sexual battery at the hands of a school

authority figure, as a result of Defendant Clearwater Academy’s employee, agent, member, and/or

representative’s violation of Florida Statutes section 800.101.

116. Defendant Clearwater Academy is thus negligent per se and liable to Plaintiff for

all damages to which Plaintiff may be entitled under applicable law, which include, but are not

20
limited to, bodily injury and resulting pain and suffering, disability, mental anguish, loss of

capacity for the enjoyment of life, medical treatment, medical expenses, and loss of income.

117. Defendant Clearwater Academy is vicariously liable for the sexual battery

committed by its employee, agent, member, and/or representative because the employee, agent,

member, and/or representative committed the batteries in the course and scope of his employment

and for the benefit and interest of Defendant Clearwater Academy and in keeping with Clearwater

Academy’s teachings and instructions.

118. Defendant Clearwater Academy is vicariously liable for the sexual batteries

committed by its employee, agent, member, and/or representative because the employee, agent,

member, and/or representative was assisted in accomplishing the batteries upon Plaintiff by and

through the existence of his employee/employer relationship with Defendant Clearwater

Academy.

119. Plaintiff reserves the right, upon the proper showing of record evidence, to amend

the Complaint to seek punitive damages resulting from Defendant Clearwater Academy’s

employee, agent, member, and/or representative’s intentional, wanton, and willful acts, and gross

negligence, for which Clearwater Academy is vicariously liable.

WHEREFORE, Plaintiff demands judgment for damages against Defendant Clearwater

Academy, together with the costs of this action and such further relief as the Court deems

appropriate. Plaintiff further demands trial by jury of all issues triable as of right.

COUNT V
NEGLIGENCE AGAINST CLEARWATER
ACADEMY INTERNATIONAL

120. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

21
121. At all times material, Clearwater Academy owned, operated, managed, controlled,

and/or maintained a school serving grades pre-kindergarten through twelfth and had a duty to

supervise and protect from harm students attending Clearwater Academy.

122. At all times material, Plaintiff was a student at Clearwater Academy, which was

exclusively for the children of Scientology employees, agents, servants, members, and/or

representatives.

123. At all times material, Clearwater Academy owed a duty to its students to operate,

manage, control, and/or maintain the school in a reasonably safe manner and to protect students,

including Plaintiff, from unreasonable risk of physical and mental harm.

124. At all times material, Clearwater Academy had an additional duty to exercise due

care in hiring, training, retaining, and/or supervising its employees, agents, servants, members,

and/or representatives who were involved with the care, instruction, and supervision of students.

125. Clearwater Academy breached the aforementioned duties and/or negligently and

carelessly failed to discharge the aforementioned duties by, among other things:

a. failing to protect Clearwater Academy’s students, including Plaintiff, from


the unreasonable risk of physical and mental harm;

b. failing to hire employees, agents, servants, members, and/or representatives


that were appropriately qualified to teach, care, monitor, and supervise
students, including Plaintiff;

c. failing to appropriately investigate employees, agents, servants, members,


and/or representatives prior to hiring them and/or allowing them to interact
with, supervise, and care for students;

d. failing to properly supervise its employees, agents, servants, members,


and/or representatives and ensure that, among other things, its employees,
agents, servants, members, and/or representatives were following proper
policies and procedures and were adequately caring for, monitoring,
instructing, and/or supervising the students entrusted to their care, including
Plaintiff;

22
e. failing to investigate students’ claims of sexual battery, including Plaintiff’s
claims;

f. failing to prevent sexual batteries upon students, including Plaintiff, even


after obtaining direct knowledge that such batteries were taking place;

g. failing to discharge, reassign, and/or remove certain of its employees,


agents, servants, members, and/or representatives from its premises even
after Plaintiff reported to other Clearwater Academy employees, agents,
servants, members, and/or representatives the sexual battery she was
subjected to on multiple occasions at the hands of Clearwater Academy
employees, agents, servants, members, and/or representatives.

126. Clearwater Academy had actual notice that its employees, agents, servants,

members, and/or representatives were unfit because Plaintiff informed Clearwater Academy that

she was subjected to sexual battery on multiple occasions at the hands of Clearwater Academy

employees, agents, servants, members, and/or representatives. It was unreasonable for Clearwater

Academy to retain the subject employees, agents, servants, members, and/or representatives after

these instances of sexual battery were made known to it.

127. As a direct and proximate result of Clearwater Academy’s negligent hiring,

retention, and supervision, and/or of the negligence that is vicariously attributed to it, Plaintiff

suffered serious and permanent injuries.

128. Defendant Clearwater Academy is therefore liable to Plaintiff for all damages to

which Plaintiff may be entitled under applicable law, which include, but are not limited to, bodily

injury and resulting pain and suffering, disability, mental anguish, loss of capacity for the

enjoyment of life, medical treatment, medical expenses, and loss of income.

129. Plaintiff reserves the right, upon the proper showing of record evidence, to amend

the Complaint to seek punitive damages resulting from Defendant Clearwater Academy’s

intentional, wanton, and willful acts, and gross negligence.

23
WHEREFORE, Plaintiff demands judgment for damages against Defendant Clearwater

Academy, together with the costs of this action and such further relief as the Court deems

appropriate. Plaintiff further demands trial by jury of all issues triable as of right.

COUNT VI
BREACH OF FIDUCIARY DUTY AGAINST
CLEARWATER ACADEMY

130. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

131. Defendant Clearwater Academy owed Plaintiff a fiduciary duty due to the trust and

confidence existing between them as student and school. Plaintiff relied upon, trusted, and reposed

confidence in Defendant Clearwater Academy, and Defendant Clearwater Academy accepted

Plaintiff’s trust and confidence.

132. Based upon this relationship of trust and confidence, Defendant Clearwater

Academy had a duty to act in the best interest of Plaintiff.

133. Defendant Clearwater Academy breached that duty when it failed to act with the

utmost good faith, fairness, and honesty towards Plaintiff and/or with the highest and finest loyalty

towards Plaintiff.

134. Specifically, Clearwater Academy breached its fiduciary duty when Clearwater

Academy failed to protect Plaintiff from the batteries inflicted upon her by Clearwater Academy’s

employees, agents, servants, members, and/or representatives, for whom Clearwater Academy is

vicariously liable, even after Clearwater Academy acquired direct and actual knowledge that such

batteries were occurring.

135. As a direct and proximate result of Clearwater Academy’s breach of the fiduciary

duty it owed Plaintiff, Plaintiff suffered serious and permanent injuries.

24
136. Defendant Clearwater Academy is therefore liable to Plaintiff for all damages to

which Plaintiff may be entitled under applicable law, which include, but are not limited to, bodily

injury and resulting pain and suffering, disability, mental anguish, loss of capacity for the

enjoyment of life, medical treatment, medical expenses, and loss of income.

137. Plaintiff reserves the right, upon the proper showing of record evidence, to amend

the Complaint to seek punitive damages resulting from Defendant Clearwater Academy’s

intentional, wanton, and willful acts, and gross negligence.

WHEREFORE, Plaintiff demands judgment for damages against Defendant Clearwater

Academy, together with the costs of this action and such further relief as the Court deems

appropriate. Plaintiff further demands trial by jury of all issues triable as of right.

COUNT VII
VIOLATIONS OF THE FLORIDA RACKETEERING
AND INFLUENCE CORRUPTION ACT AGAINST
FLAG SERVICE, CSI, RTC, AND DAVID MISCAVIGE

138. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

139. Defendants Flag Service, CSI, RTC, and Miscavige are all engaged, individually

and collectively, as part of the entity known as the “Church of Scientology.” The Church of

Scientology constitutes an “enterprise” as that term is defined in Florida Statutes, section

895.02(5).

140. Plaintiff brings this claim against Defendants Flag Service, CSI, RTC, and

Miscavige under Florida Statutes, sections 895.01, et seq., and 772.101, et seq.

141. Plaintiff is a “person” with standing to sue as used in Florida Statutes, section

772.104.

25
142. Defendants Flag Service, CSI, RTC, and Miscavige, with criminal intent, engaged

in criminal human trafficking activity when they committed, attempted to commit, conspired to

commit, solicited, coerced, and/or intimidated others, including Scientology members, agents,

employees, representatives, servants, affiliates, and/or personnel, to solicit, harbor, entice, recruit,

coerce, maintain, and/or obtain Plaintiff for the purpose of exerting control over Plaintiff and

subjecting her to forced labor and services in the Sea Org for their financial benefit.

143. While Plaintiff was a Scientology member, Defendants Flag Service, CSI, RTC,

and Miscavige engaged in at least two instances of the above-described human trafficking conduct,

forcing Plaintiff and other Sea Org members into grueling physical labor and otherwise exploiting

them. Each instance of forcing Sea Org members to perform physical labor for financial gain was

facilitated or endorsed, directly or indirectly, by Defendants Flag Service, CSI, RTC, and

Miscavige or on their behalf under the same or similar interests, with the same or similar intent to

exploit the Scientology members’ work for financial gain, to achieve the same results of cheap

manual labor designed to subordinate Plaintiff and other similarly situated members through the

same or similar methods of coercion, duress, and control. The pattern of human trafficking was

performed with the same or similar accomplices facilitating the trafficking activity and the

enterprise promoted and relied on the same or similar recruitment tactics, i.e., the methods of

coercion, duress, and other unlawful means previously described, against the same victims—

unsuspecting, innocent members of Scientology and the Sea Org, like Plaintiff.

144. The last of such above-described human trafficking incidents occurred within five

years after a previous instance of human trafficking activity by Defendants Flag Service, CSI,

RTC, and Miscavige.

26
145. Defendants Flag Service, CSI, RTC, and Miscavige, with criminal intent, conspired

and/or endeavored to receive and/or derive proceeds, directly and/or indirectly, from the above-

described pattern of human trafficking activity, including the trafficking of Plaintiff.

146. Defendants Flag Service, CSI, RTC, and Miscavige, with criminal intent, did in

fact receive and/or derive proceeds, directly and/or indirectly, from the above-described pattern of

human trafficking activity, including the trafficking of Plaintiff.

147. Defendants Flag Service, CSI, RTC, and Miscavige, conspired and/or endeavored

to be employed by and/or associated with the Church of Scientology for the purpose of conducting

and/or participating, directly or indirectly, in the above-described pattern of human trafficking

activity, including the trafficking of Plaintiff.

148. Defendants Flag Service, CSI, RTC, and Miscavige, are employed by and/or

associated with the Church of Scientology to conduct and/or participate, directly or indirectly, in

the above-described pattern of human trafficking activity, including the trafficking of Plaintiff

149. As a direct and proximate result of Defendants Flag Service, CSI, RTC, and

Miscavige’s human trafficking, as described in the paragraphs above, Plaintiff has suffered

significant damage to be determined at trial.

150. Defendants Flag Service, CSI, RTC, and Miscavige are therefore liable to Plaintiff

pursuant to Florida Statutes section 772.104.

WHEREFORE, Plaintiff demands judgment for damages against these Defendants,

together with the costs of this action and such further relief as the Court deems appropriate.

Plaintiff further demands trial by jury of all issues triable as of right.

COUNT VIII
FALSE IMPRISONMENT AGAINST FLAG SERVICE,
CSI, RTC, AND DAVID MISCAVIGE

27
151. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

152. Defendants Flag Service, CSI, RTC, and Miscavige unlawfully and without legal

authority restrained and deprived Plaintiff of her liberty against her will and without her consent.

153. Plaintiff was not free and/or did not reasonably believe she was free to leave the

place where Defendants Flag Service, CSI, RTC, and Miscavige restrained her and there was no

reasonable means of escape available to Plaintiff.

154. The unlawful restraint and deprivation of Plaintiff’s liberty imposed by Defendants

Flag Service, CSI, RTC, and Miscavige was intentional and was unreasonable and unwarranted

under the circumstances.

155. When Defendants Flag Service, CSI, RTC, and Miscavige prevented Plaintiff from

leaving the place where Defendants Flag Service, CSI, RTC, and Miscavige restrained her, and/or

forced her to return to that location, they were acting with the knowledge that Plaintiff’s restraint

would, to a substantial certainty, result.

156. As a direct and proximate result of Defendants Flag Service, CSI, RTC, and

Miscavige’s false imprisonment, as described in the paragraphs above, Plaintiff has suffered

significant damage to be determined at trial.

157. Defendants Flag Service, CSI, RTC, and Miscavige are therefore liable to Plaintiff

for all damages to which Plaintiff may be entitled under applicable law, which include, but are not

limited to, bodily injury and resulting pain and suffering, disability, mental anguish, loss of

capacity for the enjoyment of life, medical treatment, medical expenses, and loss of income.

28
158. Plaintiff reserves the right, upon the proper showing of record evidence, to amend

the Complaint to seek punitive damages resulting from Defendants Flag Service, CSI, RTC, and

Miscavige’s intentional, wanton, and willful acts, and gross negligence.

WHEREFORE, Plaintiff demands judgment for damages against these Defendants,

together with the costs of this action and such further relief as the Court deems appropriate.

Plaintiff further demands trial by jury of all issues triable as of right.

COUNT IX
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
AGAINST ALL DEFENDANTS

159. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

160. Defendants’ wrongful conduct described herein was intentional, outrageous, and/or

reckless, and Defendants intended their behavior when they knew or should have known that

Plaintiff would suffer severe emotional distress as a result thereof. In fact, Defendants specifically

intended that their wrongful conduct cause Plaintiff severe emotional distress.

161. Defendants’ wrongful conduct described herein served no legitimate purpose and,

instead, was outrageous in that it went beyond all bounds of decency and the conduct was shocking,

atrocious, and utterly intolerable in a civilized community.

162. Defendants’ wrongful conduct was carried out with malicious motive and includes

but is not limited to the following:

a. refusing to protect Plaintiff from sexual battery and abuse when they had
direct knowledge that such batteries and abuse were being committed upon
Plaintiff and while Plaintiff was a minor and unable to prevent the batteries
and abuses herself;

b. tampering with Plaintiff’s vehicle, including cutting her brake lines;

c. vandalizing Plaintiff’s property;

29
d. following, shadowing, spying, eavesdropping, stalking, and surveilling
Plaintiff; and

e. conducting hundreds of spam/crank phone calls to Plaintiff’s phone.

163. As a direct and proximate result of Defendants’ outrageous conduct, as described

in the paragraphs above, Plaintiff has suffered severe emotional distress.

164. Defendants are therefore liable to Plaintiff for all damages to which Plaintiff may

be entitled under applicable law, which include, but are not limited to, bodily injury and resulting

pain and suffering, disability, mental anguish, loss of capacity for the enjoyment of life, medical

treatment, medical expenses, and loss of income.

165. Plaintiff reserves the right, upon the proper showing of record evidence, to amend

the Complaint to seek punitive damages resulting from Defendants’ intentional, wanton, and

willful acts, and gross negligence.

WHEREFORE, Plaintiff demands judgment for damages against Defendants, together

with the costs of this action and such further relief as the Court deems appropriate. Plaintiff further

demands trial by jury of all issues triable as of right.

COUNT X
INVASION OF PRIVACY AGAINST DEFENDANTS FLAG SERVICE, CSI,
RTC, AND DAVID MISCAVIGE

166. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

167. Plaintiff is and was a private person and, at the time of many of the wrongful acts

described herein, a minor.

30
168. Defendants Flag Service, CSI, RTC, and Miscavige regularly, repeatedly, and with

malicious motive invaded Plaintiff’s right to privacy by intruding on her physical and mental

solitude by, without Plaintiff’s consent, doing the following, among other things:

a. tampering with Plaintiff’s vehicle, including cutting her brake lines;

b. vandalizing Plaintiff’s property;

c. following, shadowing, spying, eavesdropping, stalking, and surveilling


Plaintiff; and

d. conducting hundreds of spam/crank phone calls to Plaintiff’s phone.

169. In so doing the acts described above, Defendants Flag Service, CSI, RTC, and

Miscavige acted in a vicious and malicious manner not reasonably limited to a legitimate purpose.

170. As a direct and proximate result of Defendants Flag Service, CSI, RTC, and

Miscavige’s invasion of Plaintiff’s privacy, as described in the paragraphs above, Plaintiff has

suffered significant damage to be determined at trial.

171. Defendants Flag Service, CSI, RTC, and Miscavige are therefore liable to Plaintiff

for all damages to which Plaintiff may be entitled under applicable law, which include, but are not

limited to, bodily injury and resulting pain and suffering, disability, mental anguish, loss of

capacity for the enjoyment of life, medical treatment, medical expenses, and loss of income.

172. Plaintiff reserves the right, upon the proper showing of record evidence, to amend

the Complaint to seek punitive damages resulting from Defendants Flag Service, CSI, RTC, and

Miscavige’s intentional, wanton, and willful acts, and gross negligence.

WHEREFORE, Plaintiff demands judgment for damages against these Defendants,

together with the costs of this action and such further relief as the Court deems appropriate.

Plaintiff further demands trial by jury of all issues triable as of right.

COUNT XI

31
CIVIL CONSPIRACY AGAINST ALL DEFENDANTS

173. Plaintiff incorporates and references the averments contained above as though fully

set forth herein.

174. Defendants knowingly, willfully, with malicious motive, and by coercion through

numbers conspired and agreed among themselves to engage in unlawful acts, including but not

limited to: (1) obstructing justice by withholding the facts of the sexual assaults inflicted upon

Plaintiff from civil authorities; (2) physically and constructively invading Plaintiff’s privacy;

and/or (3) intentionally inflicting emotional distress upon Plaintiff. The conspiracy continues to

this day.

175. In furtherance of said conspiracy and agreement, Defendants engaged in overt and

wrongful acts, including but not limited to information suppression, coercion, deception, stalking,

harassment, surveillance, threats, vandalism, theft, and/or fraud.

176. Defendants’ actions, set forth in the preceding paragraphs and incorporated herein,

were in violation of Plaintiff’s rights and committed by Defendants in furtherance of the

aforementioned conspiracies and agreements. Moreover, each of the Defendants lent aid and

encouragement and knowingly financed, ratified, and/or adopted the acts of the other.

177. As a direct and proximate result of Defendants’ conspiracy, as described in the

paragraphs above, Plaintiff has suffered significant damage to be determined at trial.

178. Defendants are therefore liable to Plaintiff for all damages to which Plaintiff may

be entitled under applicable law, which include, but are not limited to, bodily injury and resulting

pain and suffering, disability, mental anguish, loss of capacity for the enjoyment of life, medical

treatment, medical expenses, and loss of income.

32
179. Plaintiff reserves the right, upon the proper showing of record evidence, to amend

the Complaint to seek punitive damages resulting from Defendants’ intentional, wanton, and

willful acts, and gross negligence.

WHEREFORE, Plaintiff demands judgment for damages against Defendants, together

with the costs of this action and such further relief as the Court deems appropriate. Plaintiff further

demands trial by jury of all issues triable as of right.

Date: September 18, 2019. PODHURST ORSECK, P.A.


SunTrust International Center
One SE Third Avenue, Suite 2300
Miami, FL 33131
Telephone: (305) 358-2800
Fax: (305) 358-2382

By: /s Ricardo M. Martinez-Cid


RICARDO M. MARTÍNEZ-CID
Florida Bar No. 383988
Email: RMCTeam@podhurst.com
LEA P. BUCCIERO
Florida Bar No. 84763
Email: RMCTeam@podhurst.com

-&-

Brian D. Kent, Esq.


Gaetano D’Andrea, Esq.
M. Stewart Ryan, Esq.
Helen L. Fitzpatrick, Esq.
Lauren Stram, Esq.
LAFFEY, BUCCI & KENT, LLP
1435 Walnut Street, Suite 700
Philadelphia, PA 19102
(215) 399-9255/Fax: (215) 241-8700
(Pro Hac Vice admission pending for
all attorneys)

-&-

Jeffrey P. Fritz, Esq.


SOLOFF & ZERVANOS, P.C.
1525 Locust Street, 8th Floor

33
Philadelphia, PA 19102
(215) 732-2260/Fax: (215) 732-2289
(Pro Hac Vice admission pending)

-&-

Marci Hamilton, Esq.


University of Pennsylvania7
Fox-Fels Building
3814 Walnut Street
Philadelphia, PA 19104
(215) 353-8984/Fax: (215) 493-1094
(Pro Hac Vice admission pending)

-&-

Robert W. Thompson, Esq.


Kristen A. Vierhaus, Esq.
THOMPSON LAW OFFICES, P.C.
700 Airport Boulevard, Suite 160
Burlingame, CA 94010
(650) 513-6111/Fax: (650) 513-6071
(Pro Hac Vice admission pending)

Attorneys for the Plaintiffs

7
This address is solely for delivery purposes. It does not indicate support for any lawsuit or case by the
University of Pennsylvania.

34

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