8 : 5 3 LAW OFFICES OF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION LONG BEACH, CALIFORNIA 80802 e ee BARRY VAN SICKLE, ESQ., SBN 98645 1079 SUNRISE AVENUE, SUITE B-315 ROSEVILLE, CA 95661 : TELEPHONE: (916) 549-8784 Al EMAIL: barryvansickle@comcast .net FEB 2- 2010 METZGER LAW GROUP A PROFESSIONAL LAW CORPORATION orm at, Lectin RAPHAEL METZGER, ESQ., SBN 116020 ey. 5 Deputy 401 E. OCEAN BLVD., SUITE 800 ee LONG BEACH, CA 90802-4966 ‘TELEPHONE: | ($62) 437-4499 TELECOPIER: (562) 436-1561 Attorneys for Plaintiff Laura Ann DeCrescenzo SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT LAURA ANN DeCRESCENZO, aka LAURA A, DIECKMAN, CASE NO. BC4i1018 Assigned to the Honorable Ronald M. Sohigian, Dept. 41 Plaintiffs, SECOND AMENDED _—COMPLAINT vs. ASSERTING CAUSES OF ACTION FOR: CHURCH OF SCIENTOLOGY INTERNATIONAL, a corporate entity, RELIGIOUS TECHNOLOGY CENTER, previously sued herein as Doe No. 1, a California corporation, AND DOES 2 - 20, (1) FORCED ABORTION IN VIOLATION OF ARTICLE I, SECTION 1 OF THE CALIFORNIA CONSTITUTION; (2) FORCED ABORTION IN VIOLATION OF COMMON LAW; (3) DEPRIVATION OF LIBERTY IN VIOLATION OF ARTICLE I, SECTION 1 OF THE CALIFORNIA CONSTITUTION; (4) FALSE IMPRISONMENT; (5) INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; (6) VIOLATION OF LABOR CODE §§ 970 AND 1194; AND (7) VIOLATION OF BUSINESS & PROFESSIONS CODE § 17200 Defendants. DEMAND FOR JURY TRIAL [MADE PURSUANT TO CALIFORNIA CODE 0 CIVIL PROCEDURE §§ 600 ET SEQ. AND PURSUANT TO RULE 38 OF THE FEDERAL RULES OF CIVIL PROCEDURE SHOULD THIS CASE EVER BE REMOVED TO FEDERAL COURT) SECOND ANENDED COMPLAINTLaw OFFices oF RAPHAEL METZGER a 5 i 5 5 § 7 LONG BEACH, CALIFORNIA 90802-4966 401 EAST OCEAN BOULEVARD, SUITE #00 8s 21 Plaintiff, Laura Ann DeCrescenzo, hereby alleges: ‘THE PARTIES 1. At all material times hereto, Plaintiff, Laura Ann DeCrescenzo, resided and worked in the State of California. 2. Plaintiff is informed and believes and thereon alleges that Defendant, Church of Scientology International ("CSI"), is a California corporation, which at all material times hereto, was doing business in the County of Los Angeles, State of California. 3. Plaintiff is informed and believes and thereon alleges that Defendant, Religious Technology Center (*RTC”), previously sued herein as Doe No. 1, is a California corporation, which at all material times hereto, was doing business in the County of Los Angeles, State of California. 4. The true names and capacities of Defendants Does 2 through 20 are unknown to Plaintiff, who therefore sues said defendants by such fictitious names. Plaintiff will amend this complaint to state the true names and capacities of said fictitious defendants when they have been ascertained. Plaintiff is informed and believes and thereon alleges that Defendants Does 2 through 20 are in some manner responsible for the occurrences herein alleged, and that Plaintiff's damages as herein alleged were proximately caused by their conduct. i “ i dd 2 SECOND AMENDED COMPLAINTRAPHAEL METZGER A PROFESSIONAL LAW CORPORATION : 5 GENERAL ALLEGATIONS 5. From approximately 1991 to 2004, Plaintiff was employed by Defendant, CSI. During this time, Plaintiff worked and lived at Defendant, CSI’s facilities located in Los Angeles, California. Plaintiff started working for Defendant, CSI, at age twelve and continued working for Defendant, CsI, until age twenty- five. As alleged in detail below, during Plaintiff’s employment, Defendant, CSI, deprived Plaintiff of her rights to privacy and liberty, intentionally caused Plaintiff severe emotional distress, and failed to pay Plaintiff minimum wage or post required wage orders. 6. Plaintiff also worked for Defendant, RTC. Defendant, RTC, was responsible for and directly oversaw a number of the policies and conditions of Plaintiff's employment. Moreover, one or more top RTC executives were actively involved in drafting and using bogus forms, releases, and purported contracts to scare and intimidate its employees, including Plaintif£, even though Defendant, RTC, knew that said forms and waivers were unenforceable and contrary to law. “ “ “ “Wt ae “ “ tt 3 SECOND AMENDED COMPLAINTwe LAW OFFICES OF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 400 EAST OCEAN BOULEVARD, SUITE 800 LONG BEACH, CALIFORNIA 90802-4968 Br S se 3B Ra 8 & RB e oe EIRST CAUSE OF ACTION FOR FORCED ABORTION IN VIOLATION OF PLAINTIFF‘S RIGHT OF PRIVACY UNDER ARTICLE I, SECTION 1 OF THE CALIFORNIA CONSTITUTION (By Plaintiff, Laura Ann DeCrescenzo, Against All Named Defendants and Does 2-20) 7. During Plaintiff’s employment with Defendants, she became pregnant on one occasion in approximately 1996. Plaintiff was seventeen years old at the time she became pregnant. 8. Defendants forced Plaintiff to have an abortion by threatening Plaintiff with losing her job, housing, and losing her || husband if she did not have an abortion. Further, Defendants li threatened that upon losing her job, Plaintiff would owe Defendants la “Preeloader Debt,” which is a supposed debt that Plaintiff would owe Defendants for purported Scientology training and services Plaintiff was subjected to these threats for two days straight. 9. At all material times hereto, Defendants have had an internal policy of coercing and forcing their female employees, including Plaintiff, to have abortions, so as to maximize the |, Workioad from female employees and to avoid child care issues i 10. As a direct and proximate result of Defendants’ coercion and threats of terminating Plaintiff's job, threats that Plaintiff would never again see her husband, and threats that Plaintiff would incur a substantial debt, Plaintiff had an abortion in approximately 1996. 11. Plaintiff had a reasonable expectation of privacy in | deciding whether to continue her pregnancy or to have an abortion JA woman’s right of privacy in deciding whether or not to bear 4 SECOND AMENDED COMPLAINTLAW OFFICES OF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 40} EAST OCEAN BOULEVARD, SUITE £00 LONG BEACH, CALIFORNIA 90802-4966 children is one of the most intimate and fundamental of all constitutional rights because it follows from repeated acknowledgments of the Supreme Court and other courts of this state of a right to privacy in matters related to marriage, family, and sex. 12. Defendants invaded Plaintiff’s right of privacy in deciding whether to continue her pregnancy or to have an abortion by forcing Plaintiff to have an abortion or risk losing her job and housing, risk never seeing her husband again, and risk incurring a substantial debt. 13. Defendants’ conduct in forcing Plaintiff to have an abortion was a serious invasion of Plaintiff's privacy because it stripped Plaintiff of one of the most intimate and fundamental of all constitutional rights, which is a woman’s right to privacy in deciding whether or not to bear children. It is well-established that this right of personal choice is central to a woman’s control not only of her own body, but also to the control of her social role and personal destiny, Particularly in the workplace, a woman has a heightened right of privacy in deciding whether or not to bear children. 14. As a direct and proximate result of Defendant's conduct in forcing Plaintiff to have an abortion or risk losing her job and housing, risk losing her husband, and risk incurring a substantial debt, Plaintiff suffers from severe emotional distress, including anxiety, embarrassment, humiliation, shame, depression, feelings of powerlessness, and anguish Mt di 5 SECOND AMENDED COMPLAINTBON Cera s RAPHAEL METZGER LONG BEACH, CALIFORNIA 90802-4966 e © rceccxmnorrcom i tes 15. Defendants’ conduct in forcing Plaintiff to have an abortion or risk losing her job and housing, risk losing her husband, and risk incurring a significant debt, was a substantial factor in causing Plaintiff's severe emotional distress. 16. Plaintiff seeks damages for her emotional distress in a sum to be established according to proof. Further, Plaintiff seeks an injunction against forced abortions in violation of the right to privacy and reasonable attorney's fees according to proof. This claim is made for the public good and to discourage this outrageous conduct from continuing in the future. 17. Prom approximately 1996 to 2004, Plaintiff could not reasonably have discovered that she had a claim for forced abortion in violation of her constitutional right of privacy because Plaintiff was enmeshed in a confidential relationship with Defendants and was brainwashed by Defendants such that she had no comprehension of her legal rights. The confidential relationship that existed between Plaintiff and Defendants, as well as the brainwashing to which Plaintiff was subjected, are demonstrated by the following (A) Plaintiff was recruited by Defendants when she was the tender age of nine while living in New Mexico, and moved away from her family to live and work at Defendants’ facilities in California when she was a mere twelve years old. During Defendants’ recruitment of Plaintiff, Plaintiff was led to believe that her life at Defendants’ facilities would remain relatively normal - specifically, Plaintiff believed that she would continue to get an education, that she would be allowed to visit her parents with ease, and that one day, she could have children and a family of her own Plaintiff also believed that she would receive training in 6 SECOND AMENDED COMPLAINTLAW OFFICES OF RAPHAEL METZGER A PROFESSIONAL, LAW CORPORATION 401 EAST OCEAN BOULEVARD, SUITE we aan SRRRPORREBSPCSARFBEBEHR AS e @ rercensioncinrcon nie tater Scientology and would be allowed to move “up the bridge” of Scientology. Plaintiff therefore signed a "billion year contract" with Defendants at age twelve (B) Once Plaintiff began living at Defendants’ | facilities, Defendants severely restricted Plaintiff's access to the outside world. Plaintiff had limited and restricted access to email, telephones, the internet, or uncensored television. Defendants also opened, read, and censored all mail. (c) Even Plaintiff’s access to her parents was restricted, as Plaintiff only was allowed to leave Defendants’ facilities upon receiving special permission from Defendants, which rarely was granted. Each time before Plaintiff left Defendants’ facilities and each time before Plaintiff returned to Defendants’ facilities, she was required to undergo a security checking procedure (known as a “sec check”). During a sec check, Plaintiff was, among other things, interrogated by Defendants using a primitive lie detector known as an “e-meter.” The information that Plaintiff disclosed during these interrogations was documented by written means and/or recorded by video or audio means. Sec checks are used to gather and record confidential and embarrassing information, and to wear a worker’s resistance down by hours of repetitive and intrusive questioning. Plaintiff was subjected to sec checks on numerous other occasions during her employment with Defendants as well, as Defendants deemed appropriate. Mt i i ee 7 i] SECOND AMENDED COMPLAINTLAW OFFICES OF RAPHAEL METZGER EAST OCEAN BOULEVARD, SUITE 800 TONG BEACH, CALIFORNIA 20802+4% wane 10 u 12 B 14 15 16 17 18 19 20 21 2 2B 24 25 26 (D) Plaintifé had little formal education or sophistication. At the time Plaintiff began living at Defendants’ facilities, she had only a seventh grade education, and contrary to | Defendants’ representations, Plaintiff received no formal education while living at Defendants’ facilities. (3) Plaintiff was entirely dependent on Defendants for her sustenance, shelter, and income. (F) Defendants commanded a rigid work schedule from Plaintiff; Plaintiff worked seven days a week, often for 100 or more hours, at below minimum wage. During Plaintiff’s entire employment with Defendants, Plaintiff routinely and consistently was deprived of her sleep and required to stay up for days on end. (6) To punish Plaintiff for various purported wrongs during her employment, Defendants sent Plaintiff to the Rehabilitation Project Force ("RPF”) where Defendants forced Plaintiff to work under harsh conditions and perform manual labor. At the RPF, Plaintiff also was not allowed to leave without special permission, had no freedom of movement, was almost constantly under guard and being watched, and was subjected to near total deprivation of personal liberties. Plaintiff was confined to the RPF for several years of her employment. (H) Defendants forbade Plaintiff from reading or thinking anything negative about the Church of Scientology. This was enforced through the isolation tactics detailed above, as well as through the constant threat of sec checks and other forms of punishment, such as the RPF. Mt dt 8g SECOND AMENDED COMPLAINTCowan eon u i j « § 3k ah ab 82 a sy i g é i ; 3 E 5 — ExsT OCEAN BOULEVARI (1) Plaintiff spent the entirety of her formative years at Defendants’ facilities, from age twelve to age twenty-five, and was isolated from mainstream society during this entire period. (J) During her thirteen years at Defendants’ various facilities (from age twelve to age twenty-five), Plaintiff's female co-workers regularly were ordered by Defendants to have abortions, and Plaintiff believed these abortions and Defendants’ ordering of these abortions were standard protocol. 18. In 2004, Plaintiff learned that after years of work in the RPF and after completing all of the tasks required of her to be released from the RPF multiple times over, Plaintiff would not be allowed to leave the RPF. Broken and fearful of a continued stay in the RPF, Plaintiff could no longer tolerate living and working at Defendants’ facilities and determined that she had to escape. To get out of Defendants’ facilities and end her employment, Plaintiff faked suicide 19. Upon learning of Plaintiff's suicidal actions, Defendants agreed that Plaintiff could leave their facilities and end her employment. However, before Plaintiff could leave Defendants’ facilities in 2004, Plaintiff was required to sign certain documents Defendants represented to Plaintiff that by signing these documents, Plaintiff released any and all claims she had against Defendants and that these documents required Plaintiff to keep certain information “confidential,” and that if Plaintiff did not keep this information “confidential,” she would be subject to paying significant penalties/fines. Defendants knew at the time that Plaintiff signed these documents that they were unenforceable and contrary to law. However, Defendants regularly use these types of forms and documents 9 SECOND AMENDED COMPLAINTLAW OFFICES OF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 40t EAST OCEAN BOULEVARD, SUITE 800 TONG BEACH, CALIFORNIA 90802-4968 to scare and intimidate their employees into believing that they have no legal rights against Defendants, and intended that Plaintiff would rely on these documents in that fashion. 20. Plaintiff believed she would not be allowed to leave Defendants’ facilities in 2004 unless she signed these documents, and | further believed that she had given up any and all claims she had against Defendants by signing these documents (even though she remained unaware of these claims at that time). Plaintiff was never given copies of the documents that she signed. However, attached as Exhibit “A” are a true and correct copies of documents signed by individuals similarly situated to Plaintiff, which Plaintiff is informed and believes and thereon alleges are reasonably similar to the documents that Plaintiff was coerced into signing by Defendants upon leaving their facilities. 21. From approximately 2004 to July 2008, Plaintiff, to her detriment, reasonably believed that she did not have any legal xights or claims against Defendants because of the documents that she signed upon leaving Defendants’ facilities and because of Defendants’ representations with respect to said documents. During this time, 2004 to 2008, Plaintiff remained a loyal follower of the Church of Scientology. As a follower, Plaintiff was forbidden from reading or thinking anything negative about Scientology. Further, Plaintiff was threatened with rigorous sec checks, and was threatened with being deemed a "Suppressive Person" if she in any way was perceived to be an enemy of Scientology. As a "Suppressive Person," Plaintiff would have been forbidden contact with her friends and family who remained at Defendants’ facilities and who continued practicing Scientology, and would have been subjected to harassment by Defendants. Indeed, 10 SECOND AMENDED COMPLAINTRAPHAEL METZGER Fa 52 ae 38 2 3: gh 3 when Plaintiff left Defendants’ facilities in 2004, she was informed that she owed Defendant, CSI, approximately $120,000 for her on-the-job training since age twelve; this is commonly referred to by the Church of Scientology as a “Freedloader Debt." Plaintiff continued paying this purported “Freeloader Debt" well after leaving Defendants’ facilities in 2004 based upon her genuine belief in Defendants’ representations regarding her legal rights and obligations. Moreover, Plaintiff continued to purchase the Church of Scientology's literature and assisted local missions in collect ing “donations” for the Church of Scientology. 22. In approximately July 2008, when using a family member's computer, Plaintiff discovered a web page minimized on the screen that appeared to be an “8x-Scientologist” message board. Plaintiff confronted her family member regarding this page, as she and her family members were forbidden by the Church of Scientology from reading or thinking anything negative about Scientology. Initially, her family member explained that this page was simply stumbled across by accident. However, within days, Plaintiff's relatives sat her down to explain that they disagreed with a number of things that had happened in Scientology and that happened to Plaintiff while she was living at Defendants’ facilities. These | family members then showed Plaintiff a number of internet message boards, where Plaintiff discovered the stories of friends who had lived and worked at the same facilities of Defendants as Plaintiff. // Vs WW “ iL SECOND AMENDED COMPLAINT8 RAPHAEL METZGER A PROFESSIONAL LAW CORPOR ATION E g 3 i i 3 j hon eae It was only after listening to the concerns of her family members and veading the stories of her friends in July 2008 that Plaintiff realized that she might have legal claims against Defendants and that | the documents and “confidentiality” agreements she was coerced into signing by Defendants in 2004 were potentially invalid. SECOND CAUSE OF ACTION FOR FORCED ABORTION IN VIOLATION OF PLAINTIFF'S RIGHT OF PRIVACY UNDER CALIFORNIA COMMON LAW (By Plaintiff, Laura Ann DeCrescenzo, Against All Named Defendants and Does 2-20) 23. During Plaintiff’s employment with Defendants, she became pregnant on one occasion in approximately 1996. Plaintiff was seventeen years old at the time she became pregnant. 24. Defendants forced Plaintiff to have an abortion by threatening Plaintiff with losing her job, housing, and losing her husband if she did not have an abortion. Further, Defendants threatened that upon losing her job, Plaintiff would owe Defendants a ‘Freeloader Debt,” which is a supposed debt that Plaintiff would owe Defendants for purported Scientology training and services. Plaintiff was subjected to these threats for two days straight. 25. Defendants have an internal policy of forcing and coercing their female employees, including Plaintiff, to have abortions, so as to maximize the workload from female employees and to avoid child care issues. “t Ws 12 ‘SECOND AMENDED COMPLAINTRAPHAEL METZGER 401 EAST OCEAN BOULEVARD, SUITE 800 TONG BEACH, CALIFORNIA 20802-4068, wk BN Cer Res Seacoast aC en BR Bsewrsaaerases 23 24 26. As a direct and proximate result of Defendants’ coercion and threats of terminating Plaintiff's job, threats that Plaintiff lose her housing, threats that Plaintiff would never again see her husband, and threats that Plaintiff would incur a substantial debt, Plaintiff had an abortion in approximately 1996. 27. Plaintiff had a reasonable expectation of privacy in deciding whether to continue her pregnancy or to have an abortion. A woman’s right of privacy in deciding whether or not to bear children is one of the most intimate and fundamental of all privacy rights because it follows from repeated acknowledgments by the Supreme Court and courts of this State of a right to privacy in matters related to marriage, family, and sex. 28. Defendants intentionally intruded into Plaintiff's private affairs and concerns in deciding whether to continue her pregnancy or have an abortion by ordering Plaintiff to have an abortion or risk losing her job and housing, risk losing her husband, and risk incurring a substantial debt. 29. Defendants’ intrusion into Plaintiff’s private decision of whether to continue her pregnancy or to have an abortion would be highly offensive to a reasonable person. A woman’s right of privacy in deciding whether or not to bear children is one of the most intimate and fundamental of all privacy rights; this right is central to a woman's control not only of her own body, but also to the control of her social role and personal destiny. Further, in the workplace, there is a héightened sense and expectation of privacy as to matters concerning family and sex. i Mf 13 SECOND AMENDED COMPLAINTe oe 1 | 30. As a direct and proximate result of Defendants’ 2 || conduct in forcing Plaintiff to have an abortion or risk losing ner 3. || job and housing, risk losing her husband, and risk incurring substantial debt, Plaintiff suffers from severe emotional distress, including anxiety, embarrassment, humiliation, shame, depression, feelings of powerlessness, and anguish. 4 5 6 7 31. Defendants’ conduct in forcing Plaintiff to have an 8 || abortion or risk losing her job and housing, risk losing her husband, 9 and risk incurring significant debt was a substantial factor in causing Plaintiff's severe emotional distress eeu 32. Plaintiff seeks damages for her emotional distress in abe 12 || a sum to be established according to proof. ebe 3 33. From approximately 1996 to 2004, Plaintiff could not bai8e 14 || reasonably have discovered that she had a claim for forced abortion uBike 15 |] in violation of her common law right of privacy because Plaintiff was eeee 16 |/enmeshed in a confidential relationship with Defendants and was «3617. || brainwashed by Defendants such that she had no comprehension of her 18 |} 1egal rights. The confidential relationship that existed between 19 || plaintiff and Defendants, as well as the brainwashing to which 20 || Plaintiff was subjected, are demonstrated by the following: 21 (A) Plaintiff was recruited by Defendants when she 22 || was the tender age of nine while living in New Mexico, and moved away 23. || from her family to live and work at Defendants’ facilities in 24 || california when she was a mere twelve years old. During Defendants’ 25 || recruitment of Plaintiff, Plaintiff was led to believe that her life 26 |/at Defendants’ facilities would remain relatively normal - 27. || specifically, Plaintiff believed that she would continue to get an 28%] education, that she would be allowed to visit her parents with ease, 14 SECOND AMENDED COMPLAINTRAPHAEL METZGER LONG BEACH, CALIFORNIA s0802-4908 RRPERRBVISREIRAESH SS ew yay 27 and that one day, she could have children and a family of her own. Plaintiff also believed that she would receive training in Scientology and would be allowed to move “up the bridge” of Scientology. Plaintiff therefore signed a "billion year contract" with Defendants at age twelve. (B) Once Plaintiff began living at Defendants’ facilities, Defendants severely restricted Plaintiff’s access to the outside world. Plaintiff had limited and restricted access to email, telephones, the internet, or uncensored television. Defendants opened, read, and censored all mail (c) Even Plaintiff’s access to her parents was restricted, as Plaintiff only was allowed to leave Defendants’ facilities upon receiving special permission from Defendants, which rarely was granted. ach time before Plaintiff left Defendants’ facilities and each time before Plaintiff returned to Defendants’ facilities, she was required to undergo a security checking procedure {known as a “sec check"). During a sec check, Plaintiff was, among other things, interrogated by Defendants using a primitive lie detector known as an “e-meter." The information that Plaintiff disclosed during these interrogations was documented by written means and/or recorded by video or audio means. Sec checks are used to gather and record confidential and embarrassing information, and to wear a worker's resistance down by hours of repetitive and intrusive questioning. Plaintiff was subjected to sec checks on numerous other eccasions during her employment with Defendants as well, as Defendants deemed appropriate. tt Mt 15 SECOND AMENDED COMPLAINTCaran een LAW OFFICES OF RAPHAEL METZGER 1 PROFESSIONAL LAW CORPORATION LONG BEACH, CALIFORNIA 80802- (D) Plaintiff had little formal education or sophistication. At the time Plaintiff began living at Defendants’ facilities, she had only a seventh grade education, and contrary to Defendants’ representations, Plaintif£ received no formal education while living at Defendants’ facilities. (2) Plaintiff was entirely dependent on Defendants for her sustenance, shelter, and income. (F) Defendants commanded a rigid work schedule from Plaintiff; Plaintiff worked seven days a week, often for 100 or more hours, at below minimum wage. During Plaintiff's entire employment with Defendants, Plaintiff routinely and consistently was deprived of her sleep and required to stay up for days on end. (G) To punish Plaintiff for various purported wrongs during her employment, Defendants sent Plaintiff to the Rehabilitation Project Force ("RPF") where Defendants forced Plaintiff to work under harsh conditions and perform manual labor At the RPF, Plaintiff also was not allowed to leave without special permission, had no freedom of movement, was almost constantly under guard and being watched, and was subjected to near total deprivation of personal liberties. Plaintiff was confined to the RPF for several years of her employment. (H) Defendants forbade Plaintiff from reading or thinking anything negative about the Church of Scientology. This was enforced through the isolation tactics detailed above, as well as through the constant threat of sec checks and other forms of punishment, such as the RPF. i eA 16 SECOND AMENDED COMPLAINTz : : RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 408 EAST OCEAN BOULEVARI | e os . (I) Plaintiff spent the entirety of her formative years at Defendants’ facilities, from age twelve to age twenty-five, and was isolated from mainstream society during this entire period. (3) During her thirteen years at Defendants’ various facilities (from age twelve to age twenty-five), Plaintiff's female | co-workers regularly were ordered by Defendants to have abortions, and Plaintiff believed these abortions and Defendants’ ordering of these abortions were standard protocol. 34. In 2004, Plaintiff learned that after years of work in the RPP and after completing all of the tasks required of her to be released from the RPF multiple times over, Plaintiff would not be allowed to leave the RPF. Broken and fearful of a continued stay in the RPF, Plaintiff could no longer tolerate living and working at Defendants’ facilities and determined that she had to escape. To get out of Defendants’ facilities and end her employment, Plaintiff faked suicide. 35. Upon learning of Plaintiff's suicidal actions, Defendants agreed that Plaintiff could leave their facilities and end her employment. However, before Plaintiff could leave Defendants’ facilities in 2004, Plaintiff was required to sign certain documents. Defendants represented to Plaintiff that by signing these documents, Plaintiff released any and all claims she had against Defendants and that these documents required Plaintiff to keep certain information “confidential,” and that if Plaintiff did not keep this information “confidential,” she would be subject to paying significant penalties/fines. Defendants knew at the time that Plaintiff signed these documents that they were unenforceable and contrary to law. However, Defendants regularly use these types of forms and documents 7 ‘SECOND AMENDED COMPLAINTGS OF 5k3 gine gee Suz 248 axe ee z 401 EAST OCEAN BOULEVARD, SUITE 800 LONG BEACH, CALIFORNIA 20802-4068, 28% | e © memoir neta to scare and intimidate their employees into believing that they have no legal rights against Defendants, and intended that Plaintiff would rely on these documents in that fashion. 36. Plaintiff believed she would not be allowed to leave Defendants’ facilities in 2004 unless she signed these documents, and further believed that she had given up any and all claims she had against Defendants by signing these documents (even though she remained unaware of these claims at that time). Plaintiff was never given copies of the documents that she signed. However, attached as Exhibit ‘A" are a true and correct copies of documents signed by individuals similarly situated to Plaintiff, which Plaintife is informed and believes and thereon alleges are reasonably similar to the documents that Plaintiff was coerced into signing by Defendants upon leaving their facilities. 37. From approximately 2004 to July 2008, Plaintiff, to her detriment, reasonably believed that she did not have any legal rights or claims against Defendants because of the documents that she signed upon leaving Defendants’ facilities and because of Defendants’ representations with respect to said documents. During this time, 2004 to 2008, Plaintiff remained a loyal follower of the Church of Scientology. As a follower, Plaintiff was forbidden from reading or thinking anything negative about Scientology. Further, Plaintiff was threatened with rigorous sec checks, and was threatened with being deemed a "Suppressive Person" if she in any way was perceived to be an enemy of Scientology. As a "Suppressive Person," Plaintiff would have been forbidden contact with her friends and family who remained at Defendants’ facilities and who continued practicing Scientology, and would have been subjected to harassment by Defendants. Indeed, 18 ‘SECOND AMENDED COMPLAINTRAPHAEL METZGER 401 EAST OCEAN BOULEVAR 2 2 : when Plaintiff left Defendants’ facilities in 2004, she was informed that she owed Defendant, CSI, approximately $120,000 for her on-the-job training since age twelve; this is commonly referred to by the Church of Scientology as a “Freedloader Debt.” Plaintiff continued paying this purported “Freeloader Debt” well after leaving Defendants’ facilities in 2004 based upon her genuine belief in Defendants’ representations regarding her legal rights and obligations. Moreover, Plaintiff continued to purchase the Church of Scientology’s literature and assisted local missions in collecting “donations” for the Church of Scientology. 38. In approximately July 2008, when using a family member's computer, Plaintiff discovered a web page minimized on the screen that appeared to be an “Ex-Scientologist” message board Plaintiff confronted her family member regarding this page, as she and her family members were forbidden by the Church of Scientology from reading or thinking anything negative about Scientology. Initially, her family member explained that this page was simply stumbled across by accident. However, within days, Plaintiff's relatives sat her down to explain that they disagreed with a number of things that had happened in Scientology and that happened to Plaintiff while she was living at Defendants’ facilities. These family members then showed Plaintiff a number of internet message boards, where Plaintiff discovered the stories of friends who had lived and worked at the same facilities of Defendants as Plaintiff. Tt was only after listening to the concerns of her family members and it uf Mt 19 ‘SECOND AMENDED COMPLAINT |e @ econimanoiccansove rtnt 8334 1 || reading the stories of her friends in July 2008 that Plaintiff ! Bite 2 | realized that she might have legal claims against Defendants and that ' 3d 3 || the documents and “confidentiality” agreements she was coerced into | i 4 signing by Defendants in 2004 were potentially invalid. | Oe | THIRD CAUSE OF ACTION ' 7 FOR DEPRIVATION OF LIBERTY IN VIOLATION OF : 8 ARTICLE I, SECTION 1 OF THE CALIFORNIA CONSTITUTION | 9 (By Plaintiff, Laura Ann DeCrescenzo, | 10 Against All Named Defendants and Does 2-20) | eee 2 39. Prom approximately July 2001 to April 2004, Defendante ee 13. || interfered with Plaintiff's constitutional right of liberty set forth , ace: 14 || in article I, Section 1 of the California Constitution by confining _ tebe 1s || plaintict to the Rehabilitation Project Force (*RPF”) by means of | ©55216 || threats, intimidation, and coercion. ' <38 7 40. In approximately July 2001, Plaintiff was informed by 18 || Defendants that she was being sent to the RPF for having committed 19 || purported wrongs. At that time, Plaintiff refused to go to the RPF 20 || and informed Defendants that she wanted to leave their facilities. 21 ||imstead of allowing Plaintiff to leave, Defendants “handled” vee 22 || plaintiff and threatened that if she did not go to the RPF, Plaintift we 23 || would lose her job and housing, Plaintiff would incur substantial | ork? 24 || “Preeloader" debt, Plaintiff would no longer be able to associate . He 25 with any of her friends and co-workers at Defendants’ facilities, and Bo |v ' ee a Wis he “ 1 20 SECOND AMENDED COMPLAINT: e © rerersimornecomce mint | that Defendants would disclose embarrassing information about Plaintiff that was obtained during sec checks. Defendants’ coercion and repeated threats went on for a period of a week or more, at which z : > time, Plaintiff finally gave in and was transported to the RPF. i 41, Once Plaintiff arrived at the RPF, she again decided not allowed to leave, and instead, Defendants made Plaintiff stay up 4 5 6 || that she did not want to be there and asked to leave. Plaintiff was 7 8 || for hours on end, and threatened, intimidated, and coerced Plaintiff 9 into staying at the RPF. Defendants again threatened that Plaintire | 10 || would lose her job and housing, incur substantial “Freeloader” debt, ay 11 || Piaintitt would no longer be able to associate with any of her | abe 12. || friends and co-workers at Defendants’ facilities, and that Defendants ab 13. || would disclose embarrassing information about Plaintiff that was | baage 14 |] obtained during sec checks. ' SEuke 1s 42. The RPF was brutal, and Plaintiff was forced to work : ebce 16 || under harsh conditions and perform manual labor. Indeed, on at least <35 17 || one occasion, Plaintiff was instructed to clean a large trash ' 18 |] dumpster with a toothbrush. When Plaintiff purportedly acted out in ! 19 || the RPF, she was punished by being forced to run around the basement 20 of the building where the RPF was located or do push-ups. 21 43. Plaintiff was typically guarded while in the RPF. | 22 || Indeed, Plaintiff was restricted to the building where the RPF was 23. || located, and was only allowed outside the building on authorized work 24 |Il cycles. When and if Plaintiff traveled from building to building, | she was accompanied by a security guard or control group. When 26 || Plaintiff used the phone, her conversations typically were monitored 27 \lby a security guard. 28 Sx) // 1 21 SECOND AMENDED COMPLAINT 'sure. LAW OFFICES OF RAPHAEL METZGER 3 a i z ; 5 i i ee S 44, Plaintiff reasonably believed that if she exercised her right of liberty and attempted to leave the RPF, Defendants would retaliate against Plaintiff. Specifically, Plaintiff recalls having to sign a bond with Defendants, whereby Plaintiff would owe Defendants one million dollars or ten million dollars for “each breach of security." Moreover, given Defendants’ repeated threats, Plaintiff reasonably believed that if she left the RPF, she would lose her job and housing, incur substantial “Freeloader” debt, would no longer be able to associate with any of her friends or co-workers at Defendants’ facilities, and that Defendants would disclose embarrassing information about Plaintiff that was obtained during her sec checks. Plaintiff knew from experience that once someone left Defendants’ facilities, she never again saw, heard from, or spoke to those individuals. 45. As a direct and proximate result of Defendants’ interference with Plaintiff’s constitutional right of liberty whereby Plaintiff was confined to the RPF for several years of her life as a result of Defendants’ repeated threats, intimidation, and coercion, Plaintiff suffers from severe emotional distress, including anxiety, embarrassment, humiliation, shame, depression, feelings of powerlessness, and anguish. 46. Defendants’ conduct in interfering with Plaintiff’s constitutional right of liberty by means of threats, intimidation, and coercion was a substantial factor in causing Plaintiff's severe emotional distress. 47. Plaintiff seeks damages for her emotional distress in a sum to be established according to proof. Further, Plaintiff seeks an injunction against future confinement and deprivation of liberty 22 SECOND AMENDED COMPLAINTRAPHAEL METZGER 401 EAST OCEAN BOULEVARD, SUITE 800 LONG BEACH, CALIFORNIA 80802-4966 e e econ ei by means of threats, coercion, and intimidation on the part of Defendants, and reasonable attorney's fees according to proof. This claim is made for the public good and to discourage this outrageous conduct from continuing in the future 48. In 2004, Plaintiff learned that after years of work in the RPF and after completing all of the tasks required of her to be released from the RPF multiple times over, Plaintiff would not be allowed to leave the RPF. Broken and fearful of a continued stay in the RPF, Plaintiff could no longer tolerate living and working at Defendants’ facilities and determined that she had to escape. To get out of Defendants’ facilities and end her employment, Plaintiff faked suicide. 49. Upon learning of Plaintiff’s suicidal actions, Defendants agreed that Plaintiff could leave their facilities and end her employment. However, before Plaintiff could leave Defendants’ facilities in 2004, Plaintiff was required to sign certain documents. Defendants represented to Plaintiff that by signing these documents, Plaintiff released any and all claims she had against Defendants and that these documents required Plaintiff to keep certain information “confidential,” and that if Plaintiff did not keep this information “confidential,” she would be subject to paying significant penalties/fines. Defendants knew at the time that Plaintiff signed these documents that they were unenforceable and contrary to law. However, Defendants regularly use these types of forms and documents to scare and intimidate their employees into believing that they have no legal rights against Defendants, and intended that Plaintiff would rely on these documents in that fashion. “ih 23 SECOND AMENDED COMPLAINTRAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 401 EAST OCEAN BOULEVARD, SUITE. 50. Plaintiff believed she would not be allowed to leave Defendants’ facilities in 2004 unless she signed these documents, and further believed that she had given up any and all claims she had against Defendants by signing these documents (even though she yemained unaware of these claims at that time). Plaintiff was never given copies of the documents that she signed. However, attached as Exhibit "A" are a true and correct copies of documents signed by individuals similarly situated to Plaintiff, which Plaintiff is inforited and believes and thereon alleges are reasonably similar to the documents that Plaintiff was coerced into signing by Defendants upon leaving their facilities. 51. From approximately 2004 to July 2008, Plaintiff, to her detriment, reasonably believed that she did not have any legal rights or claims against Defendants because of the documents that she signed upon leaving Defendants’ facilities and because of Defendants’ representations with respect to said documents. During this time, 2004 to 2008, Plaintiff remained a loyal follower of the Church of Scientology. As a follower, Plaintiff was forbidden from reading or thinking anything negative about Scientology. Further, Plaintiff was threatened with rigorous sec checks, and was threatened with being deemed a “Suppressive Person" if she in any way was perceived to be an enemy of Scientology. As a "Suppressive Person," Plaintiff would have been forbidden contact with her friends and family who remained at Defendants’ facilities and who continued practicing Scientology, and would have been subjected to harassment by Defendants. Indeed, when Plaintiff left Defendants’ facilities in 2004, she was informed that she owed Defendant, CSI, approximately $120,000 for her on-the-job training since age twelve; this is commonly referred to 24 SECOND AMENDED COMPLAINT& & Bn ah au 32 ig a es 3E g é 3 ; 8 H 8 5 40) EAST OCEAN BOULEVARD, SUITE 800 LONG BEACH, CALIFORNIA 90802: g Cea anew Ss e © srrcenssinccanmie aint by the Church of Scientology as a “Freedloader Debt." Plaintiff continued paying this purported “Freeloader Debt” well after leaving Defendants’ facilities in 2004 based upon her genuine belief in Defendants’ representations regarding her legal rights and obligations. Moreover, Plaintiff continued to purchase the Church of Scientology's literature and assisted local missions in collecting “donations” for the Church of Scientology. 52. In approximately July 2008, when using a family member’s computer, Plaintiff discovered a web page minimized on the screen that appeared to be an “Ex-Scientologist” message board Plaintiff confronted her family member regarding this page, as she and her family members were forbidden by the Church of Scientology from reading or thinking anything negative about scientology. Initially, her family member explained that this page was simply stumbled across by accident. However, within days, Plaintiff's relatives sat her down to explain that they disagreed with a number of things that had happened in Scientology and that happened to Plaintiff while she was living at Defendants’ facilities. These family members then showed Plaintiff a number of internet message boards, where Plaintiff discovered the stories of friends who had lived and worked at the same facilities of Defendants as Plaintiff It was only after listening to the concerns of her family members and reading the stories of her friends in July 2008 that Plaintiff realized that she might have legal claims against Defendants and that the documents and “confidentiality” agreements she was coerced into signing by Defendants in 2004 were potentially invalid. “ Mt 25 SECOND AMENDED COMPLAINT2 3 3 er a a) BGS LAW OFFICES OF RAPHAEL METZGER ‘A PROFESSIONAL LAW CORPORATION LONG BEACH, CALIFORNIA 99802-404 Bre 8s RPBepR SRRR e @ vvrcscercenmine renin EOURTH CAUSE OF ACTION FOR FALSE IMPRISONMENT (By Plaintiff, Laura Ann DeCrescenzo, Against All Named Defendants and Does 2-20) 583 Between July 2001 and April 2004, Defendants intentionally confined Plaintiff to the Rehabilitation Project Force (°RPE”) by means of unreasonable duress. 54. In approximately July 2001, Plaintiff was informed by Defendants that she was being sent to the RPF for having committed purported wrongs. At that time, Plaintiff refused to go to the RPF and informed Defendants that she wanted to leave their facilities. Instead of allowing Plaintiff to leave, Defendants ‘handled” Plaintiff and threatened that if she did not go to the RPP, Plaintiff would lose her job and housing, Plaintiff would incur substantial ~Breeloader” debt, Plaintiff would no longer be able to associate with any of her friends and co-workers at Defendants’ facilities, and that Defendants would disclose embarrassing information about Plaintiff that was obtained during sec checks. Defendants’ coercion and repeated threats went on for a period of a week or more, at which time, Plaintiff finally gave in and was transported to the RPF. 55. Once Plaintiff arrived at the RPF, she again decided that she did not want to be there and asked to leave, Plaintiff was not allowed to leave, and instead, Defendants made Plaintiff stay up for hours on end, and threatened, intimidated, and coerced Plaintiff into staying at the RPF, Defendants again threatened that Plaintiff would lose her job and housing, incur substantial “Freeloader” debt, Plaintiff would no longer be able to associate with any of her 26 SECOND AMENDED COMPLAINTRAPHAEL METZGER 401 EAST OCEAN BOULEVARD, SUITE 800 Ce a awe CONG BEACH, CALIFORNIA 90802-4965, Re stack ip ace ae gael teat et eee tet at cence ttt ee RRRRERBRRESSEVDRRETBSrBS 285 e @ vrrcnssracxccanise emt friends and co-workers at Defendants’ facilities, and that Defendants would disclose embarrassing information about Plaintiff that was obtained during sec checks. Although Plaintiff thereafter remained at the RPF, Plaintiff was not capable of, and did not, voluntarily consent to her confinement at the RPF. 56. Plaintiff was watched almost constantly while at the RPF, Indeed, Plaintiff was restricted to the building where the RPF was located, and was only allowed outside the building on authorized work cycles. When and if Plaintiff traveled from building to building, she was accompanied by a security guard, and when Plaintiff used the phone, her conversations were monitored by a security guard. Plaintiff was not permitted to speak to anyone, unless spoken to first. 57. As a direct and proximate result of Defendants’ intentional confinement of Plaintiff, Plaintiff suffers from severe emotional distress, including anxiety, embarrassment, humiliation, shame, depression, feelings of powerlessness, and anguish. 58. Defendants’ conduct of intentionally confining Plaintiff to the RPF without her consent was a substantial factor in causing Plaintiff’s severe emotional distress. 59. Plaintiff seeks damages for her emotional distress in a sum to be established according to proof. 60. In 2004, Plaintiff learned that after years of work in the RPF and after completing all of the tasks required of her to be released from the RPF multiple times over, Plaintiff would not be allowed to leave the RPF. Broken and fearful of a continued stay in the RPF, Plaintiff could no longer tolerate living and working at Defendants’ facilities and determined that she had to escape. To get 27 SECOND AMENDED COMPLAINT« & BR gS 2h ge Ea by iE & é i g § 5 i : 401 EAST OCEAN BOULEVARD, SUITE. e © vrrenntnccriomse tin out of Defendants’ facilities and end her employment, Plaintiff faked suicide. 61. Upon learning of Plaintiff's suicidal actions, Defendants agreed that Plaintiff could leave their facilities and end her employment. However, before Plaintiff could leave Defendants’ facilities in 2004, Plaintiff was required to sign certain documents Defendants represented to Plaintiff that by signing these documents, Plaintiff released any and all claims she had against Defendants and that these documents required Plaintiff to keep certain information “confidential,” and that if Plaintif£ did not keep this information “confidential,” she would be subject to paying significant penalties/fines. Defendants knew at the time that Plaintiff signed these documents that they were unenforceable and contrary to law. However, Defendants regularly use these types of forms and documents to scare and intimidate their employees into believing that they have no legal rights against Defendants, and intended that Plaintiff would xely on these documents in that fashion. 62. Plaintiff believed she would not be allowed to leave Defendants’ facilities in 2004 unless she signed these documents, and further believed that she had given up any and all claims she had against Defendants by signing these documents (even though she xemained unaware of these claims at that time). Plaintiff was never given copies of the documents that she signed. However, attached as Exhibit “A” are a true and correct copies of documents signed by individuals similarly situated to Plaintiff, which Plaintiff is informed and believes and thereon alleges are reasonably similar to the documents that Plaintiff was coerced into signing by Defendants upon leaving their facilities. 28 SECOND AMENDED COMPLAINTRAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 40} EAST OCEAN BOULEVARD, SUITE 800 RON e © rrcserimensssion ns re 63. From approximately 2004 to July 2008, Plaintiff, to her detriment, reasonably believed that she did not have any legal rights or claims against Defendants because of the documents that she signed upon leaving Defendants’ facilities and because of Defendants’ representations with respect to said documents. During this time, 2004 to 2008, Plaintiff remained a loyal follower of the Church of Scientology. As a follower, Plaintiff was forbidden from reading or thinking anything negative about Scientology. Further, Plaintiff was threatened with rigorous sec checks, and was threatened with being deemed a "Suppressive Person" if she in any way was perceived to be an enemy of Scientology. As a "Suppressive Person," Plaintiff would have been forbidden contact with her friends and family who remained at Defendants’ facilities and who continued practicing Scientology, and would have been subjected to harassment by Defendants. Indeed, when Plaintiff left Defendants’ facilities in 2004, she was informed that she owed Defendant, CSI, approximately $120,000 for her on-the-job training since age twelve; this is commonly referred to by the Church of Scientology as a “Freedloader Debt.” Plaintiff continued paying this purported “Freeloader Debt” well after leaving Defendants’ facilities in 2004 based upon her genuine belief in Defendants’ representations regarding her legal rights and obligations. Moreover, Plaintiff continued to purchase the Church of Scientology's literature and assisted local missions in collecting “donations” for the Church of Scientology 64. In approximately July 2008, when using a family member’s computer, Plaintiff discovered a web page minimized on the screen that appeared to be an “Ex-Scientologist” message board. Plaintiff confronted her family member regarding this page, as she 29 SECOND AMENDED COMPLAINTRAPHAEL METZGER 401 EAST OCEAN BOULEVARD, SUL LONG BEACH, CALIFORNIA 9080: and her family members were forbidden by the Church of Scientology from reading or thinking anything negative about Scientology Initially, her family member explained that this page was simply stumbled across by accident. However, within days, Plaintiff's yelatives sat her down to explain that they disagreed with a number of things that had happened in Scientology and that happened to Plaintiff while she was living at Defendants’ facilities. These family members then showed Plaintiff a number of internet message boards, where Plaintiff discovered the stories of friends who had lived and worked at the same facilities of Defendants as Plaintiff. It was only after listening to the concerns of her family members and reading the stories of her friends in July 2008 that Plaintiff realized that she might have legal claims against Defendants and that the documents and “confidentiality” agreements she was coerced into signing by Defendants in 2004 were potentially invalid FIFTH CAUSE OF ACTION FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (By Plaintiff, Laura Ann DeCrescenzo, Against All Named Defendants and Does 2-20) 65. During Plaintiff's employment with Defendants from approximately 1991 to 2004, Defendants intended to cause Plaintiff severe emotional distress. “ut uw us Mt 30 SECOND AMENDED COMPLAINTa e e | EE 66. Defendants’ conduct that was intended’ to cause 1 AH 2 || Plaintiff severe emotional distress includes Defendants’ repeated i $124 3 || interrogations of Plaintiff while performing purported “sec checks" t He 4 || and Defendants’ supposed punishment and rehabilitation of Plaintiff ie 5 || in the RPF. i aaaeaes 67. As described in preceding paragraphs, security 1 7 || checking or sec checking is a process whereby an employee, such as : 8 || Plaintiff, is interrogated on a primitive lie detector known as an | 9 e-meter. This process is designed and employed to make sure that the «10 || worker has no thoughts of trying to escape or becoming a Scientology an 11 |] risk. Employees such as Plaintiff are told, and come to believe, 1 uBR 12. || that they can have no secrets from Defendants’ management. Any such | Se 13 |l secrets or bad thoughts will be exposed in “sec checks" on the ' $aige 14 |le-meter. This process started for Plaintiff on or before her first ; Eee 15 || planned visit with her parents at age twelve and continued for her ; epee 16 || thirteen years of working for Defendants. “38 7 68. The sec checks performed by Defendants on Plaintiff 18 || were invasive, degrading, and abusive. Plaintiff was interrogated i 19 || by Defendants for hours, occasionally day after day, and was forced 1 20 ||and coerced into confessing embarrassing information. The : 21 || intormation that Plaintiff disclosed was then documented by written i 22 means and/or recorded by video or audio means. Defendants thereafter 23. || threatened Plaintiff with disclosing this embarrassing information 24 || when Defendants detected that Plaintiff wanted to leave their 25 || facilities, was failing to comply with Defendants’ policies, or when 26 || Defendants felt that Plaintiff was a risk to Scientology. 27 uf 28 2) // 31 SECOND AMENDED COMPLAINT: : & fi 38 AS 28 EE ga a FF: i E é 5 i 8 E 8 401 EAST OCEAN BOULEVARD, SUITE 800 CONG BEACH, CALIFORNIA s0#02-4a66 ea aw 69. As described in preceding paragraphs, Plaintiff also was forced to spend several years of her employment with Defendants in the RPF, from July 2001 to April 2004. In the RPF, Plaintiff was forced to do manual labor and live under incredibly harsh conditions. Indeed, on at least one occasion, Plaintiff was instructed to clean a large trash dumpster with a toothbrush. When Plaintiff purportedly acted out in the RPF, she was punished by being forced to run around the basement of the building where the RPF was located or do push- ups. In addition, Plaintiff's pay, which already was below minimum wage, was docked by Defendants while she worked in the RPF. 70, Likewise, Plaintiff was watched almost constantly while in the RPF. Plaintiff was restricted to the building where the RPF was located, and was only allowed outside the building on authorized work cycles. When and if Plaintiff traveled from building to building, she was accompanied by a security guard, and when Plaintiff used the phone, her conversations were monitored by a security guard. Plaintiff was not permitted to speak to anyone, unless spoken to first. This confinement and Defendants’ almost constant watch over Plaintiff lasted for over two and half years of the time that Plaintiff lived and worked at Defendants’ facilities. 71, Defendants’ conduct in subjecting Plaintiff to lengthy, harassing, and degrading interrogations or “sec checks” was outrageous and was in reckless disregard of the probability of causing Plaintiff severe emotional distress. This conduct was extreme and clearly exceeded the bounds of that usually tolerated in civilized society. Indeed, this type of conduct is not tolerated when used by police departments, let alone, when used by employers. Mt 32 SECOND AMENDED COMPLAINTRAPHAEL METZGER § ; g Z 3 é 401 EAST OCEAN BOULEVARD, SUITE 800 LONG BEACH, CALIFORNIA 80802-4966 Cer ane vn = Sse ranronts 2 22 23 24 25 26 oa 28°? e © rrcneccmerinscan ie ra 72. Defendants’ conduct in subjecting Plaintiff to years of life in the RPF also was outrageous and was in reckless disregard of the probability of causing Plaintiff severe emotional distress. The tasks that Defendants mandated Plaintiff complete and Defendants’ confinement and isolation was Plaintiff was extreme and clearly exceeded the bounds of that usually tolerated in civilized society. 73. As a direct and proximate result of Defendants’ outrageous conduct and reckless disregard, Plaintiff suffers from severe emotional distress, including anxiety, embarrassment, humiliation, shame, depression, feelings of powerlessness, and anguish. 74. Defendants‘ outrageous conduct and reckless disregard for Plaintiff was a substantial factor in causing Plaintiff's severe emotional distress. 75. plaintiff seeks damages for her emotional distress in a sum to be established according to proof 76. In 2004, Plaintiff learned that after years of work in the RPF and after completing all of the tasks required of her to be released from the RPF multiple times over, Plaintiff would not be allowed to leave the RPF. Broken and fearful of a continued stay in the RPF, Plaintiff could no longer tolerate living and working at Defendants’ facilities and determined that she had to escape. To get out of Defendants’ facilities and end her employment, Plaintiff faked suicide. 77. Upon learning of Plaintiff's suicidal actions, Defendants agreed that Plaintiff could leave their facilities and end her employment. However, before Plaintiff could leave Defendants’ facilities in 2004, Plaintiff was required to sign certain documents. 33 SECOND AMENDED COMPLAINTCaran een Ss = RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 401 EAST OCEAN BOULEVARD, SUITE. 800 TONG BEACH, CALIFORNIA 90802-4968, Bese eaz aa BEB 8 e @ rrcverinsserocar treats Defendants represented to Plaintiff that by signing these documents, Plaintiff released any and all claims she had against Defendants and that these documents required Plaintiff to keep certain information “confidential,” and that if Plaintiff did not keep this information “confidential,” she would be subject to paying significant penalties/fines. Defendants knew at the time that Plaintiff signed these documents that they were unenforceable and contrary to law However, Defendants regularly use these types of forms and documents to scare and intimidate their employees into believing that they have no legal rights against Defendants, and intended that Plaintiff would ely on these documents in that fashion. 78, Plaintiff believed she would not be allowed to leave Defendants’ facilities in 2004 unless she signed these documents, and further believed that she had given up any and all claims she had against Defendants by signing these documents (even though she xemained unaware of these claims at that time). Plaintiff was never given copies of the documents that she signed. However, attached as Exhibit "A" are a true and correct copies of documents signed by individuals similarly situated to Plaintiff, which Plaintiff is informed and believes and thereon alleges are reasonably similar to the documents that Plaintiff was coerced into signing by Defendants upon leaving their facilities. 79. From approximately 2004 to July 2008, Plaintiff, to her detriment, reasonably believed that she did not have any legal rights or claims against Defendants because of the documents that she signed upon leaving Defendants’ facilities and because of Defendants’ representations with respect to said documents. During this time, 2004 to 2008, Plaintiff remained a loyal follower of the Church of 34 SECOND AMENDED COMPLAINT2 e ! co | 1 || scientology. as a follower, Plaintiff was forbidden from reading or | 2 || thinking anything negative about Scientology. Further, Plaintiff was threatened with rigorous sec checks, and was threatened with being 4 deemed a "Suppressive Person" if she in any way was perceived to be |! 5 || an enemy of Scientology. As a "Suppressive Person," Plaintiff would | 6 || have been forbidden contact with her friends and family who remained , : 7 || at Defendants’ facilities and who continued practicing Scientology, : 8 and would have been subjected to harassment by Defendants. Indeed, i 9 || wnen plaintiff left Defendants’ facilities in 2004, she was informed 10 || that she owed Defendant, CSI, approximately $120,000 for her i \ he 11 |[ on-the-job training since age twelve; this is conmonly referred to | | BBaE 12 |[ny tne church of scientology as a “Freedloader Debt." Plaintiff | I ib 13. || continued paying this purported “Freeloader Debt” well after leaving ! sai8: 14 |lvefendants’ facilities in 2004 based upon her genuine belief in | ' uPhae 15 |lpefendants' representations regarding her legal rights and / ; abe 16 || obligations. Moreover, Plaintiff continued to purchase the Church | #3817 || of scientology’s literature and assisted local missions in collecting ! 18 || “donations” for the Church of Scientology. | 19 80. In approximately July 2008, when using a family I 20 || member's computer, Plaintiff discovered a web page minimized on the 21 || screen that appeared to be an “Ex-Scientologist” message board. 22 || Plaintiff confronted ner family member regarding this page, as she 23. || and ner family members were forbidden by the Church of Scientology 24 || from reading or thinking anything negative about Scientology. 25 || amitially, her family member explained that this page was simply stumbled across by accident. However, within days, Plaintiff's 27 || relatives sat her down to explain that they disagreed with a number 28{'|lof things that had happened in Scientology and that happened to ie 35 i SECOND AMENDED COMPLAINT0 RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 40f EAST OCEAN BOULEVARO, SUIT aaw \ tf e © cosmic tet Plaintiff while she was living at Defendants’ facilities. These family members then showed Plaintiff a number of internet message boards, where Plaintiff discovered the stories of friends who had lived and worked at the same facilities of Defendants as Plaintiff. It was only after listening to the concerns of her family members and veading the stories of her friends in July 2008 that Plaintiff realized that she might have legal claims against Defendants and that the documents and “confidentiality” agreements she was coerced into signing by Defendants in 2004 were potentially invalid. SIXTH CAUSE 0) ‘TON FOR VIOLATION OF WAGE AND HOUR LAWS SET FORTH IN CALIFORNIA LABOR CODE SECTIONS 970 AND 1194 (By Plaintiff, Laura Ann DeCrescenzo, Against All Named Defendants and Does 2-20) 81. From approximately 1991 to 2004, Plaintiff performed work for Defendants. Defendants, and each of them, controlled wages, hours, and working conditions. 82. When Defendants solicited Plaintiff to work and live at their facilities in approximately 1991, Defendants represented to Plaintiff that Plaintiff would be paid for her work, that Plaintiff would receive up to three weeks vacation per year, that Plaintiff would be allowed to visit her parents once a month, that Plaintiff would work hours consistent with being a minor, and that Plaintiff would continue to get a formal education while working at Defendants’ facilities. 36 SECOND AMENDED COMPLAINT1 83. Defendants’ representations were not true. During 2 || Plaintiff's work for Defendants from 1991 to 2004, Plaintiff was never given three weeks of vacation time per year, Plaintiff was not 4 || allowed to visit her parents once a month (indeed, Plaintiff's access to her parents was severely restricted), Plaintiff routinely worked seven days a week for 100 or more hours (which is not consistent with ° formal education. i 5 6 7 || the working hours of a minor), and Plaintiff did not receive any | 8 a | 84. Defendants knew at the time that they made the aforementioned representations to Plaintiff in 1991 that these a representations were not true. With respect to workers in et 12. || Plaintift’s position, Defendants’ have an internal policy of limiting | eb 13. || ana restricting vacation time, limiting workers’ access to their | aprtan parents and outside family, and of requiring these workers to | Pike 15 || consistently work seven days a week for 100 or more hours. Moreover, | ease 16 || because Defendants command so many working hours of their employees | <38 17 || and do not have a formal education system, Defendants knew that 18 || Plaintifs would not receive a formal education while under their 19 employ. i 20 85. Defendants further intended that Plaintiff would rely 21 || on their representations regarding Plaintiff's working conditions. uelf 22 || mis is demonstrated by the fact that Defendants solicited Plaintitr | Eh 23 || at the age of twelve to leave her family in New Mexico and move to | ei 24 || caligornia to live and work at Defendants’ facilities. i BE 26 | // : #253 “ i 37 SECOND AMENDED COMPLAINTXv RAPHAEL METZGER 401 EAST OCEAN BOULEVARD, SUITE 200 LONG BEACH, CALIFORNIA $0802"4956 86. Plaintiff reasonably relied on Defendants’ representations and moved from New Mexico to California for the purpose of working for Defendants. It is logical for a twelve year ole te believe that she will pe permitted three weeks of vacation I|time a year, that she will be allowed reasonable access to her parents, and that she will work a average work week consistent with being a minor, particularly when representations to that effect are made. Moreover, it is logical for a twelve year old to believe that she will continue to receive an education when moving to work and live away from her family at a young age; a certain level of education is mandated by law. 87. As a direct and proximate result of Defendants’ misrepresentations to Plaintiff in soliciting Plaintiff as an employee, Plaintiff suffered lost income and education. 88. As a further direct and proximate result of Defendants’ misrepresentations to Plaintiff in soliciting Plaintief as an employee, Plaintiff suffers from emotional distress, including anxiety, embarrassment, humiliation, shame, depression, feelings of powerlessness, and anguish. 89. Plaintiff’s reliance on Defendants’ aforementioned representations was a substantial factor in causing Plaintiff harm as Plaintiff would not have moved away from her home and family or foregone her formal education in the absence of relying on Defendants’ representations. 89. Plaintiff seeks to recover damages for her lost income and education and for her emotional distress in a sum to be established according to proof. Mf 38 SECOND AMENDED COMPLAINTiy gee Sng abeg 233 $038 2S52 2585 Sk i u LONG BEACH, CALIFORNIA 90802-4968 a RRRPBRBBRBRESSTREUVRRBESHR AS 90. Plaintifé also was harmed during her work for @ rercunssrcvinccon me teat Defendants because she was paid less than the minimum wage and was not paid overtime. Defendants paid Plaintiff less than the minimum wage during Plaintiff's entire employment with Defendants, from 1991 to 2004. Purther, during Plaintiff's employment with Defendants, from 1991 to 2004, Plaintiff routinely worked overtime and Defendants did not pay Plaintiff for that overtime. 91. Plaintiff seeks to recover lost wages, with interest, for all of the years that she worked for Defendants and was not paid minimum wage. 92. Plaintiff also seeks to recover overtime compensation, with interest, due her for all of her hours of unpaid overtime work for Defendants. 93. Plaintiff also seeks to recover penalties pursuant to Labor Code Section 203 in an amount equivalent to wages from the date of the cessation of Plaintiff’s employment with Defendants to the present date and to the date of judgment, because Defendants wilfully failed to pay Plaintiff wages owed to Plaintiff on the date of the cessation of her employment, have continued to fail to pay such wages to the present date, and will continue to fail to pay such wages to Plaintiff until judgment is rendered and paid in this action. 94, Plaintiff also seeks to recover reasonable attorney’s fees according to proof pursuant to applicable provisions of the Labor Code. 95. From approximately 1991 to 2004, Plaintiff could not reasonably have discovered that she had a claim against Defendants sor Defendants’ false representations in soliciting Plaintiff's employment and Defendants’ failure to pay minimum wage and overtime 39 SECOND AMENDED COMPLAINTe @ vrecersirncsnoneimse tte 2:22 | ||pay because Plaintiff was enmeshed in a confidential relationship i 2 with Defendants and was brainwashed by Defendants such that she had 3 $2 3. |] no comprehension of her legal rights. The confidential relationship HE 4 ll that existed between Plaintiff and Defendants, as well as the be 5 || brainwashing to which Plaintiff was subjected, are demonstrated by "6 |l ene sortowing: 7 (a) Plaintiff was recruited by Defendants when she 8 || was the tender age of nine while living in New Mexico, and moved away 9 || trom her family to live and work at Defendants’ facilities in ¢. 10 || california when she was a mere twelve years old. During Defendants’ ast 11 |i recruitment of Plaintiff, Plaintiff was led to believe that her life 28212 ||at vetendants’ facilities would remain relatively normal - bye 13. || specifically, Plaintiff believed that she would continue to get an aes 14 |leducation, that she would be allowed to visit her parents with ease, Eh 15. || ana that one day, she could have children and a family of her own e558 16 || Plaintiff also believed that she would receive training in «38 17 || scientology and would be allowed to move “up the bridge” of 18 |] Scientology. Plaintiff therefore signed a "billion year contract" 19 || with Defendants at age twelve. 20 (B) Once Plaintiff began living at Defendants’ 21 || facilities, Defendants severely restricted Plaintif£'s access to the 22 || outside world. Plaintiff had limited and restricted access to email, 23. || telephones, the internet, or uncensored television. Defendants 24 || opened, read, and censored all mail 2s (c) Bven Plaintiff’s access to her parents was 26 || restricted, as Plaintiff only was allowed to leave Defendants’ 27 ‘|| facilities upon receiving special permission from Defendants, which rarely was granted. Each time before Plaintiff left Defendants’ 40 SECOND AMENDED COMPLAINTao Bie Oks nee oss ey a8 as $33 mag eos ees “3 TONG BEACH, CALIFORNIA 90802-4966 e © vrencioncenconse natn facilities and each time before Plaintiff returned to Defendants’ facilities, she was required to undergo a security checking procedure (known as a “sec check”). During a sec check, Plaintiff was, among other things, interrogated by Defendants using a primitive lie detector known as an “e-meter.” The information that Plaintiff disclosed during these interrogations was documented by written means and/or recorded by video or audio means. Sec checks are used to gather and record confidential and embarrassing information, and to wear a worker’s resistance down by hours of repetitive and intrusive questioning. Plaintiff was subjected to sec checks on numerous other eccasions during her employment with Defendants as well, as Defendants deemed appropriate. (D) Plaintiff had little formal education or sophistication. At the time Plaintiff began living at Defendants’ facilities, she had only a seventh grade education, and contrary to Defendants’ representations, Plaintiff received no formal education while living at Defendants’ facilities. (s) Plaintiff was entirely dependent on Defendants for her sustenance, shelter, and income. (F) Defendants commanded a rigid work schedule from Plaintiff; Plaintiff worked seven days a week, often for 100 or more hours, at below minimum wage. During Plaintift’s entire employment with Defendants, Plaintiff routinely and consistently was deprived of her sleep and required to stay up for days on end. (G) To punish Plaintiff for various purported wrongs during her employment, Defendants sent Plaintiff to the Rehabilitation Project Force ("RPF") where Defendants forced Plaintiff to work under harsh conditions and perform manual labor 4 SECOND AMENDED COMPLAINTe © emrsamvsncecrsrt mens 1 || at the RPF, Plaintiff also was not allowed to leave without special i | | permission, had no freedom of movement, was almost constantly under guard and being watched, and was subjected to near total deprivation ao of personal liberties. Plaintiff was confined to the RPF for several | years of her employment. | (H) Defendants forbade Plaintiff from reading or thinking anything negative about the Church of Scientology. This was enforced through the isolation tactics detailed above, as well as Cea 8 through the constant threat of sec checks and other forms of t 10 || punishment, such as the RPP. it i (1) Plaintiff spent the entirety of her formative ; sue 12. || years at Defendants’ facilities, from age twelve to age twenty-five, | i auld: 13 || and was isolated from mainstream society during this entire pericd. | | : Sapga 4 96. Further, from approximately 1991 to 2004, Plaintiff , | EBREe 15 || could not reasonably have discovered that she had a claim against ; ; rr 16 || Defendants for Defendants’ failure to pay minimum wage and overtime — | «38 17 || pay, because Defendants did not post the wage and hour notices that 18 |] they legally were required to post in Plaintiff's workplace. Without 19 || these wage and hour notices, Plaintiff did not have actual notice of 5 i 20 || her rights to minimum wage and her rights to overtime compensation. | al 97. In 2004, Plaintiff learned that after years of work j 22. || in the RPF and after completing all of the tasks required of her to | 2 23. || be released from the RPF multiple times over, Plaintiff would not be : 3 24 |] allowed to leave the RPF. Broken and fearful of a continued stay in | * 25 |[the RPF, Plaintiff could no longer tolerate living and working at 3 26 ||pefendants’ facilities and determined that she had to escape. To get : 27 |\ out of Defendants’ facilities and end her employment, Plaintiff faked | 5 suicide a2 SECOND AMENDED COMPLAINT: : : RAPHAEL METZGER 401 EAST OCEAN BOULEVARD, SUITE 800 TONG BEACH, CALIFORNIA 20802-4968 ant cepee eee fege ee eee eee e @ vrecoioncvrioeinss ton 98 Upon learning of Plaintiff's suicidal actions, Defendants agreed that Plaintiff could leave their facilities and end her employment. However, before Plaintiff could leave Defendants’ facilities in 2004, Plaintiff was required to sign certain documents Defendants represented to Plaintiff that by signing these documents, Plaintiff released any and all claims she had against Defendants and that these documents required Plaintiff to keep certain information “confidential,” and that if Plaintiff did not keep this information “confidential,” she would be subject to paying significant penalties/fines. Defendants knew at the time that Plaintiff signed these documents that they were unenforceable and contrary to law However, Defendants regularly use these types of forms and documents to scare and intimidate their employees into believing that they have no legal rights against Defendants, and intended that Plaintiff would xely on these documents in that fashion 99, Plaintiff believed she would not be allowed to leave Defendants’ facilities in 2004 unless she signed these documents, and further believed that she had given up any and all claims she had against Defendants by. signing these documents (even though she remained unaware of these claims at that time), Plaintiff was never given copies of the documents that she signed. However, attached as Exhibit “A” are a true and correct copies of documents signed by individuals similarly situated to Plaintiff, which Plaintiff ic informed and believes and thereon alleges are reasonably similar to the documents that Plaintiff was coerced into signing by Defendants upon leaving their facilities. “ue us 43 SECOND AMENDED COMPLAINTe © crremermesrrae me enim LAW OFFICES OF uae 100. From approximately 2004 to July 2008, Plaintiff, to i i 2 || her detriment, reasonably believed that she did not have any legal 3)8: 3. |) eignes or claims against Defendants because of the documents that she : 2 4 || signed upon leaving Defendants’ facilities and because of Defendants’ 8 vs representations with respect to said documents. During this time, : 6 || 2004 to 2008, Plaintiff remained a loyal follower of the Church of 7 || Scientology. As a follower, Plaintiff was forbidden from reading or 8 || thinking anything negative about Scientology. Further, Plaintiff was 9 || threatened with rigorous sec checks, and was threatened with being g, 10 || deemed a “suppressive person" if she in any way was perceived to be ae 11. || an enemy of Scientology. As a "Suppressive Person," Plaintiff would Gee 12 |; have been forbidden contact with her friends and family who renained bal 13. |) at Defendants’ facilities and who continued practicing Scientology, u25 14 |] and would have been subjected to harassment by Defendants. Indeed, £55215 || wnen plaintifs left Defendants’ facilities in 2004, she was informed Se 16 || that she owed Defendant, CST, approximately $120,000 for her “8 17 || on-the-job training since age twelve; this is commonly referred to 18 || by the Church of Scientology as a “Freedloader Debt." Plaintiff 19 || continued paying this purported "Freeloader Debt” well after leaving 20 || detendants’ facilities in 2004 based upon her genuine belief in 21 || Defendants’ representations regarding her legal rights and ual 2 || obligations. Moreover, Plaintiff continued to purchase the Church ae 23 || of Scientology's literature and assisted local missions in collecting on 24 || “donations” for the Church of Scientology. ft 25. 101. In approximately July 2008, when using a family HY 26 || member’s computer, Plaintiff discovered a web page minimized on the tok 27 || screen that appeared to be an “Ex-Scientologist” message board. 2582 29:l] piaineige confronted her family member regarding this page, as she fe 44 SECOND AMENDED COMPLAINTa auwnon ee Nl 12 1B 14 Law OFFICES OF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 401 EAST OCEAN BOULEVARD, SUITE 200 15, 16 17 18 19 20 21 2 23 4 25 26 and her family members were forbidden by the Church of Scientology from reading or thinking anything negative about scientology. Initially, her family member explained that this page was simply stumbled across by accident. However, within days, Plaintiff's relatives sat her down to explain that they disagreed with a number of things that had happened in Scientology and that happened to Plaintiff while she was living at Defendants’ facilities. These family members then showed Plaintiff a number of internet message boards, where Plaintiff discovered the stories of friends who had lived and worked at the same facilities of Defendants as Plaintiff. It was only after listening to the concerns of her family members and reading the stories of her friends in July 2008 that Plaintiff realized that she might have legal claims against Defendants and that the documents and “confidentiality” agreements she was coerced into signing by Defendants in 2004 were potentially invalid. FOR EVE! "AUSE OF ACTION VIOLATION OF BUSINESS AND PROFESSIONS CODE SECTION 17200, ET SEQ. (By Plaintiff, Laura Ann DeCrescenzo, Against All Named Defendants and Does 2-20) 102. During Plaintiff’s employment with Defendants from approximately 1991 to 2004, and upon Plaintiff's termination of her employment with Defendants, Defendants engaged in unlawful, unfair and fraudulent business practices. Mt ‘“t 45 SECOND AMENDED COMPLAINT | Ie @ wrecsinimestsecnmnie ta ag 103. Defendants’ unlawful, unfair and fraudulent business aul 2 || practices include: aid 3 (A) Defendants’ internal policy of coercing and ' Hh 4 |\forcing their female employees, including Plaintiff, to have i in 5 || abortions, so as to maximize the workload from female employees and 1 F" 6 Ito avoid chizd care issues. i 7 (B) Defendants’ repeated confinement of their ' a | employees, including Plaintiff, to the RPF by means of threats, 9 || intimidation, and coercion. ee (c) Defendants’ practice of threatening to disclose | : ae 11 Jlembarrassing and confidential information about their employees, | Rie 12 |] including Plaintiff, when Defendants detect their employees want to | | gus ge 13 leave their facilities or fail to comply with Defendants’ policies | | bgz8el4 || or orders. i RBGEz 1s (D) Defendants’ practice of imposing substantial | : e58 16 || \Freeloader Debts” on former employees, including Plaintiff, for i “8 17. || purported on-the-job training, knowing that these purported debts are | : 18 || invalid and unenforceable. Defendant, CSI, imposed a $120,000 debt ¢ 19 || on Plaintig# when she left Defendants’ facilities in 2004. Plaintiff 20 || paia this debt long after leaving Defendants’ facilities : i 2 (8) Defendants’ solicitation of employees, including | | ,$2 22 |/piaintire, through false representations regarding the workers’ ' $122 93 || access to their parents, schedule, and education that they will 5 facilities. i receive as employees when working and living at Defendants’ { i 26 (F) Defendants’ policy of paying their employees, | 27. || including Plaintiff, less than the legal minimum wage Ben // ~ 46 ‘SECOND AMENDED COMPLAINTBw 2 3 3 wer au ys02-a06e RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 40 EAST OCEAN BOULEVARD, SUITE 800 LONG BEACH, CALIFORNIA (G) Defendants’ policy of requiring employees, including Plaintiff, to work more than eight hours a day and more than forty hours per week without paying these employees overtime compensation. (H) Defendants’ refusal to post Wage and Hour Notices informing their employees of their rights as workers. (1) Defendants’ practice of coercing employees, including Plaintiff, into signing documents upon their termination that purport to release all claims against Defendants, prevent employees from saying anything negative about Defendants, and purport to subject employees to significant penalties/fines if said agreements are not adhered to in full. 104. As a direct and proximate result of Defendants’ unlawful, unfair and fraudulent business practices, Plaintiff suffered lost employment income and monies which she paid to Defendants on her “freeloader debt.” 105. Defendants’ unlawful, unfair and fraudulent business practices were a substantial factor in causing Plaintiff to sustain said economic losses. 106. Plaintiff seeks restitution for unpaid wages and the monies which she paid to Defendants on her “freeloader debt,” in a sum to be established according to proof, pursuant to Business and Professions Code Sections 17200, et seq., especially Business and Professions Code Section 17204 107. Plaintiff also seeks an injunction against Defendants’ unlawful, unfair and fraudulent business practices pursuant to Business and Professions Code Sections 17200, et seq., especially Business and. Professions Code Section 17203. 47 SECOND AMENDED COMPLAINTeon ew ae RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 401 EAST OCEAN BOULEVARD, SUITE 800 LONG BEACH, CALIFORNIA 80802-4966 e @ cercersemavorcnn nie tmnt 108. Plaintiff further seeks reasonable attorney's fees according to proof pursuant to the Labor Code and pursuant to | California Code of Civil Procedure Section 1021.5 . This claim is made for the public good and to discourage this outrageous conduct from continuing in the future 109. Prom approximately 1991 to 2004, Plaintiff could not reasonably have discovered that she had a claim against Defendants for Defendants’ unfair and fraudulent business practices because Plaintiff was enmeshed in a confidential relationship with Defendants and was brainwashed by Defendants such that she had no comprehension of her legal rights. The confidential relationship that existed between Plaintiff and Defendants, as well as the brainwashing to which Plaintiff was subjected, are demonstrated by the following (A) Plaintiff was recruited by Defendants when she was the tender age of nine while living in New Mexico, and moved away from her family to live and work at Defendants’ facilities in California when she was a mere twelve years old. During Defendants’ recruitment of Plaintiff, Plaintiff was led to believe that her life at Defendants’ facilities would remain relatively normal - specifically, Plaintiff believed that she would continue to get an education, that she would be allowed to visit her parents with ease, and that one day, she could have children and a family of her own Plaintiff also believed that she would receive training in Scientology and would be allowed to move “up the bridge” of Scientology. Plaintiff therefore signed a "billion year contract" with Defendants at age twelve i Za 4B SECOND AMENDED COMPLAINTe @ rrcansimeseroenrse tte ' \ | Se 8 1 (B) Once Plaintiff began living at Defendants’ tn 2. || cacdlities, Defendants severely restricted Plaintiff's access to the gi]: 3. | outside world. Plaintiff had Limited and restricted access to email, ah 4 || telephones, the internet, or uncensored television. Defendants ue 5 || opened, read, and censored all mail 2 6 (C) Even Plaintiff's access to her parents was 7 restricted, as Plaintiff only was allowed to leave Defendants’ 8 || facilities upon receiving special permission from Defendants, which 9 rarely was granted. Each time before Plaintiff left Defendants’ 10 || facilities and each time before Plaintiff returned to Defendants’ ant 11 || facilities, she was required to undergo a security checking procedure Gees 12 |] Genown as a “sec check"). During a sec check, Plaintiff was, among be 13. |] other things, interrogated by Defendants using a primitive lie ales 14 || detector known as an “e-meter." The information that Plaintiff ‘ Ee 15 || disclosed during these interrogations was documented by written means e558 16 || and/or recorded by video or audio means. Sec checks are used to ° <3 17 || gatner and recora confidential and ‘embarrassing information, and to | 18 || wear a worker's resistance down by hours of repetitive and intrusive 19 || questioning. Plaintiff was subjected to sec checks on numerous other 20 || occasions during her employment with Defendants as well, as 21 || Defendants deemed appropriate. 22 (D) Plaintiff had little formal education or 23. || sophistication. At the time Plaintiff began living at Defendants’ 24 || facilities, she had only a seventh grade education, and contrary to 25 || Defendants’ representations, Plaintiff received no formal education 26 || while living at Defendants’ facilities 1 27 | (g) Plaintiff was entirely dependent on Defendants | 28: || for her sustenance, shelter, and income. 7 49 SECOND AMENDED COMPLAINT iLaw oFFices oF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 401 EAST OCEAN BOULEVARD, SUITE 600 LONG BEACH, CALIFORNIA so802-4068, (F) Defendants commanded a rigid work schedule from Plaintiff; Plaintiff worked seven days a week, often for 100 or more hours, at below minimum wage. During Plaintiffs entire employment with Defendants, Plaintiff routinely and consistently was deprived of her sleep and required to stay up for days on end. (G) To punish Plaintiff for various purported wrongs during her employment, Defendants sent Plaintiff to the Rehabilitation Project Force ("RPF") where Defendants forced Plaintiff to work under harsh conditions and perform manual labor. At the RPF, Plaintiff also was not allowed to leave without special permission, had no freedom of movement, was almost constantly under guard and being watched, and was subjected to near total deprivation of personal liberties. Plaintiff was confined to the RPF for several years of her employment. ({H) Defendants forbade Plaintiff from reading or thinking anything negative about the Church of Scientology. This was enforced through the isolation tactics detailed above, as well as through the constant threat of sec checks and other forms of punishment, such as the RPF. (1) Plaintiff spent the entirety of her formative years at Defendants’ facilities, from age twelve to age twenty-five, and was isolated from mainstream society during this entire period. 110. Further, from approximately 1991 to 2004, Plaintiff could not reasonably have discovered that she had a claim against Defendants for Defendants’ unfair and fraudulent business practices of failing to pay minimum wage and overtime pay because Defendants did not post the wage and hour notices that they legally were required to post in Plaintiff's workplace. Without these wage and 30 SECOND AMENDED COMPLAINThour notices, Plaintiff did not have actual notice of her rights to 5 £ 2 |/minimum wage and her rights to overtime compensation. 3 ‘ 3 111, As alleged in earlier paragraphs, in 2004, Plaintiff : : 4 | learnea that after years of work in the RPF and after completing all | 7 * 5 || of the tasks required of her multiple tines over, Plaintif£ would not | 6 || be allowed to leave the RPF. Broken and fearful of a continued stay 7 || in the RPF, Plaintiff could no longer tolerate living and working at 8 || Defendants’ facilities and determined that she had to escape. To get 9 || out of Defendants’ facilities and end her employment, Plaintiff faked | | 10 || suicide. | | 1 anf ul 112. Upon learning of Plaintiff's suicidal actions, ae 12. || Defendants agreed that Plaintiff could leave their facilities and end abe: 13. || ner employment. However, before Plaintiff could leave Defendants’ pe 14 || gacilities in 2004, Plaintiff was required to sign certain documents. j rate 15. || Defendants represented to Plaintiff that by signing these documents, ' ese 16 || ptaintife released any and all claims she had against Defendants and ze 17 | chat these documents required Plaintiff to keep certain information 18 || “confidential,” and that if Plaintiff did not keep this information | 19 || *confidential,” she would be subject to paying significant ' 20 ||penaities/fines. Defendants knew at the time that Plaintif£ signed | 21 |] enese documents that they were unenforceable and contrary to law. | 2 || wowever, Defendants regularly use these types of forms and documents | | 23 || to scare and intimidate their employees into believing that they have 24 || no legal rights against Defendants, and intended that Plaintiff would 25 || rely on these documents in that fashion. 26 113. Plaintiff believed she would not be allowed to leave 27 || Defendants’ facilities in 2004 unless she signed these documents, and 28:"|| €urther believed that she had given up any and all claims she had 31 SECOND AMENDED COMPLAINTee a LAW OFFICES OF RAPHAEL METZGER ‘A PROFESSIONAL LAW CORPORATION TONG BEACH, CALIFORNIA 80802. Reisen eee teat Besexz us R RRR against Defendants by signing these documents (even though she remained unaware of these claims at that time). Plaintiff was never given copies of the documents that she signed. However, attached as Exhibit “A” are a true and correct copies of documents signed by individuals similarly situated to Plaintiff, which Plaintiff is informed and believes and thereon alleges are reasonably similar to the documents that Plaintiff was coerced into signing by Defendants upon leaving their facilities. 114. From approximately 2004 to July 2008, Plaintiff, to her detriment, reasonably believed that she did not have any legal rights or claims against Defendants because of the documents that she signed upon leaving Defendants’ facilities. During this time, 2004 to 2008, Plaintiff remained a loyal follower of the Church of Scientology. As a follower, Plaintiff was forbidden from reading or thinking anything negative about Scientology. Further, Plaintiff was threatened with rigorous sec checks, and was threatened with being deemed a "Suppressive Person" if she in any way was perceived to be an enemy of Scientology. As a "Suppressive Person," Plaintiff would have been forbidden contact with her friends and family who remained at Defendants’ facilities and who continued practicing Scientology, and would have been subjected to harassment by Defendants. Indeed, when Plaintiff left Defendants’ facilities in 2004, she was informed that she owed Defendant, Church of Scientology International, approximately $120,000 for her on-the-job training since age twelve; this is commonly referred to by the Church of Scientology as a “Freedloader Debt.” Plaintiff continued paying this purported “Freeloader Debt” well after leaving Defendants’ facilities in 2004 based upon her genuine belief in Defendants’ representations 52 SECOND AMENDED COMPLAINT| id e . | $2g% 1 |) xegarding her egal rights and obligations. Moreover, Plaintitt ' te 2 || continued to purchase the Church of Scientology's literature and | 22: 3. |] assievea 1ocal missions in collecting “donations” for the church of | ait 4 || scientology. 7 ifs lis. In approximately guly 2008, when using a family |" 6 ||menber's computer, Plaintiff discovered a web page minimized on the i 7 || screen that appeared to be an “Ex-Scientologist” message board. | 8 || Plaintiff confronted her family member regarding this page, as she 1 9 || and her family members were forbidden by the Church of Scientology ; g, 10 || trom reading or thinking anything negative about scientology. | Be 1 || tnitially, her family member explained that this page was simply Hee 12. || stumbled across by accident. However, within days, Plaintiff’s gues 13 | relatives sat her down to explain that they disagreed with a number gales 14 | of things that had happened in Scientology and that happened to dEgdes Plaintiff while she was living at Defendants’ facilities. These i @358 16 || family members then showed Plaintiff a number of internet message ! <36 17 boards, where Plaintiff discovered the stories of friends who had ; 18 || lived and worked at the same facilities of Defendants as Plaintiff. I 19 || It was only after listening to the concerns of her family members and 20 || reading the stories of her friends in July 2008 that Plaintiff 21 || realized that she might have legal claims against Defendants and that ! val or lene Goecmenee ana scone identialicy: agceenencs ons veg coerced: into : B]42 25. || signing by Defendants in 2004 were potentially invalid. | eae? 24 Was ine 25/7 THE 26 [Lv tse ar as /iBEE 28] // ' 5 3 | SECOND ANENDED COMPLAINT 1Bown Ce ae LAW OFFICES OF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION 40t EAST OCEAN BOULEVAR! a TONG BEACH, CALIFORNIA 90802. 40% e © vrrcecemenscinevete meet PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment as follows: 1. For general damages in a sum in excess of the minimum jurisdictional amount of the court; 2. For loss of earnings according to proof; 3. For loss of education damages according to proof; 4. For emotional distress damages according to proof; 5. For unpaid wages, including interest, according to proof; 6. For injunctive relief preventing forced abortions, | Ceprivation of liberty, and unfair and fraudulent business practices; 7. For restitution of unpaid wages, unpaid overtime wages, and monies that Plaintiff paid to Defendants pursuant to Labor Code § 1194 et al., and pursuant to Bus. & Prof. Code § 17200, et al. 8. For civil penalties pursuant to Labor Code § 203 et al 9. For reasonable attorney's fees pursuant to Labor Code § 218.5 and C.C.P. § 1021.5. 10. For pre- and post~judgment interest allowed by law; 11. For Plaintiff's costs of suit incurred herein; and, 12. For such other and further relief as the Court deems | just and proper. DATE: February 2, 2010 MBTZGER LAW GROUP Corporation Attorneys for Plaintiff, Laura Ann DeCrescenzo 54 SECOND AMENDED COMPLAINTLAW OFFICES OF RAPHAEL METZGER A PROFESSIONAL LAW CORPORATION LONG BEACH, CALIFORNIA 90802-4966 Bos DE TAL Pursuant to Cal. Code of Civil Procedure § 600 et seq. (and Rule 38 of the Federal Rules of Civil Procedure should this case ever be removed to federal court), Plaintiff hereby demands trial by jury of all issues which may be tried to a jury. DATE: February 2, 2010 METZGER LAW GROUP A Professional Law Corporation METZGER, Attorneys for Pijntire, Laura Ann DeCresdenzo 55 SECOND AMENDED COMPLAINTAGREEMENT AND GENERAL RELEASE This Agreement and General Release (“Agreement”) is entered into on 3 September, 2004 by and between Claire Headley, (hereinafter “CH") on the one hand, and Religious Technology Center RTC”), a California non-profit religious corporation, on the other hand. RECITALS WHEREAS, CH is a religious worker, employed by RTC, a church of the Scientology religior WHEREAS, CH’s performance of her duties and responsibilities in connection with her employment by RTC does not justify her continued employment by RTC. WHEREAS, CH and RTC wish to have a clear statement of their respective rights, obligations, and duties upon CH’s termination from her employment by RTC and a basis upon which CH and RTC may cooperate with one another in the future; and WHEREAS, to avoid potential conflict or misunderstanding in the future between CH and RTC, NOW, THEREFORE: in consideration of the premises, promises, covenants, and warranties set forth in this Agreement, and for good and valuable consideration, the receipt of which the parties to this Agreement hereby acknowledge, CH and RTC agree as fallows: 1. Termination of Employment. ‘A. CH’s employment in any and al! capa stated above. s by RTC is hereby terminated as of the date first B. CH acknowledges and agrees that at all times throughout her employment by RTC and throughout her employment by any entity affiliated with the Scientology religion, he has been compensated in a timely manner in full accordance with all applicable laws and Scientology policy, and that she is entitled to no further compensation as a result of such employment. 2, General Release. A. Asa material inducement to RTC to enter into this Agreement, CH on behalf of herself, her heirs, her successors, representatives, agents, employees, attomneys and assigns, hereby irrevocably and unconditionally releases, acquits, and forever discharges RTC, Church of Scientology Intemational (CSI), all other Scientology Churches, Missions and Scientology affiliated organizations, their respective trustees, directors, officers, employees, and agents, individually and in any and all capacities, the successors and assigns of L. Ron Hubbard, and each of them, and their respective successors, representatives, agents, attorneys, assigns, subsidiaries, officers, directors, divisions, trustees, and 1 EXHIBIT aemployees (collectively "Releasees"), individually and in any and all capacities, from any and all claims, damages, causes of action of every kind, whether known or unknown, which CH, or any of those named above claiming under her now have or may hereafter have against Releases, and each of them, from the beginning of time, to and including the effective date of this Agreement. B. The term any and all claims" as used above, means and includes, but is not limited to, all claims of any kind, whether known or unknown, anticipated or unanticipated, suspected or "unsuspected, past or present, contingent or fixed, including, without limitation, claims under: (1) Title VII of the Civil Rights Act of 1964 (tace, color, religion, sex, and national origin discrimination); (2) 42 U.S.C. §1981 (discrimination); (3) 29 U.S.C. §§621-634 (age discrimination); (4) 29 U.S.C. §206(4)(1) (equal pay); (5) the California Fair Employment and Housing Act (discrimination, including race, color, national origin, ancestry, physical handicap, medical condition, marital status, sex, or age); (6) Executive Order 11246 (race, color, religion, sex, and national origin discrimination); (7) Executive Order 11141 (age discrimination); and (8) §§503 and 504 of the Rehabilitation Act of 1973 (handicap discrimination). C. The term “any and all claims” shall be interpreted liberally and as sufficiently comprehensive so that this Agreement precludes any and all disputes, litigation or controversy of any and all descriptions brought by CH against any and all Releasees. 3. Waiver of Civil Code Section 1542. CH acknowledges that she has read Section 1542 of the California Civil Code, which provides that: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE, CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS FAVOR AT THE TIME OF EXECUTING THIS RELEASE, WHICH IF KNOWN BY HIM MUST HAVE MATERIALLY AFFECTED HIS SETTLEMENT WITH THE DEBTOR.” CH agrees and understands that by signing this Agreement, she is releasing all claims, whether known, unknown, foreseen, or unforeseen, obvious or hidden which she may have against any of the Releasces. CH understands the above-referenced code section and its significance and consequence, and she expressly waives and relinquishes all rights and benefits she may have thereunder, as well as under any other statute or common law principles of similar effect. 4, Consideration, In exchange for her other promises, covenants, warranties and obligations set forth inthis ‘Agreement, CH acknowledges the receipt from RTC of good, valuable, and adequate consideration including, but not limited to, RTC providing CH with assistance in securing employment and RTC's commitment to assist CH in the future should others attempt to persuade, assist, or induce her to breach this agreement, which commitment RTC hereby acknowledges.5. Representations and Warranties. CH represents, warrants, and states that: A. CH has read this Agreement in its entirety and understands its contents. . CH has executed this Agreement willingly, voluntarily, and without coercion or duress of any kind, C. CH’s intent and purpose in executing this Agreement is to completely and forever disengage from any and all controversies, disputes, and proceedings of any nature with RTC, CSI and all other entities affiliated with the Scientology religion, and all individuals associated in any capacity with all such entities. CH further represents, warrants, and states that this Agreement and cach of its terms is to bbe construed liberally to effect that intention and purpose. D. CH has returned to RTC any and all confidential materials relating to the Scientology religion in her possession, custody or control. CH further represents, warrants, and states that she recognizes that she has a continuing and perpetual duty to surrender to RTC any and all such confidential materials which in the future come into her possession, custody, or control. E. CH acknowledges and reaffirms any and all agreements that she previously made with RTC and any and all confidentiality agreements that she made with any other entity affiliated with the Scientology religion and specifically acknowledges and reaffirms her continuing obligations thereunder. Attached hereto as Exhibit A is a list of such obligations, which CH acknowledges and agrees are by way of example, but not limitation, F. In executing this Agreement, CH is waiving what otherwise might be construed as rights, under the California and United States Constitutions, specifically her First Amendment right to free speech and its California equivalent. CH specifically acknowledges that she does so knowingly and ‘voluntarily with respect to all covenants, duties, and obligations she makes and acknowledges in this Agreement. G. CH acknowledges that as part of her participation in Scientology religious services, RTC and other Scientology churches that she has been affiliated with, compiled folders containing its notations of her spiritual progress, known as a “Preclear Folder” or “PC Folder,” as well as other ecclesiastical files containing notations regarding her spiritual progress. CH further acknowledges and confirms that her PC Folders and other ecclesiastical files containing notations regarding her spiritual progress, as well as all contents thereof, are the sole and exclusive property of CSI and will be held by CSI or other Scientology churches in accordance with ecclesiastical doctrine and policy and that itis a matter of religious belief and of ecclesiastical doctrine and ln, that such folders and files, and the contents of such folders and files, are kept confidential from all persons who tack the ecclesiastical authority to gain access to such materials, including CH, and are subject to all applicable clergyman-penitent privileges, and are neither compreliensible nor meant to be understood by anyone whose training and expertise in their interpretation not recognized and sanctioned by RTC.H, CH hereby forever abandons, surrenders, waives, and relinquishes without limitation any and all rights of ownership, possession, custody, control, access, copying, and viewing ofher PC Folders and all other ecclesiastical files containing any notations regarding her spiritual progress, both with respect to the folders and files themselves and the information contained in them. 1. CH confirms that the abandonment, surrender, waiver, and relinquishment referred to in the immediately preceding paragraph is unconditional and irrevocable and applies equally to anyone acting or purporting to be acting on CH’s behalf or for her benefit, whether she is alive or dead, whether she is disabled or incapacitated, and under any and all circumstances foreseen or unforeseen, in perpetuity, without exception or limitation. J. CH ACKNOWLEDGES THAT IF SHE OR ANYONE ACTING OR PURPORTING TO BE ACTING ON HER BEHALF OR FOR HER BENEFIT EVER SEEK ACCESS TO ANY OF HER PC FOLDERS OR ANY OTHER ECCLESIASTICAL FILE CONTAINING ANY NOTATIONS REGARDING HER SPIRITUAL PROGRESS, SHE INTENDS FOR THE SUBMISSION OF THIS AGREEMENT TO THE PRESIDING JUDICIAL OFFICER TO BE A COMPLETE AND SUFFICIENT BASIS FOR THE IMMEDIATE DENIAL OF WHATEVER ACCESS IS BEING SOUGHT WITH PREJUDICE TO ANY OTHER OR FURTHER EFFORT TO BREACH THE ABSOLUTE CONFIDENTIALITY OF THOSE MATERIALS OR THE EXCLUSIVE RIGHT OF CSI OR OTHER SCIENTOLOGY CHURCHES IN ACCORDANCE WITH ECCLESIASTICAL DOCTRINE AND POLICY TO PRESERVE THEIR ABSOLUTE Gee i K. CH FURTHER ACKNOWLEDGES AND CONFIRMS THAT SHOULD SHE OR ANYONE ACTING OR PURPORTING TO BE ACTING ON HER BEHALF EVER SUE, OR OTHERWISE SEEK LEGAL RECOURSE WITH RESPECT TO ANY DISPUTE, CLAIM OR CONTROVERSY AGAINST, THE CHURCH, ANY OTHER SCIENTOLOGY CHURCH, ANY OTHER ORGANIZATION WHICH ESPOUSES, PRESENTS, PROPAGATES OR PRACTICES THE, SCIENTOLOGY RELIGION, OR ANY PERSON EMPLOYED BY ANY SUCH ENTITY, REGARDLESS OF THE NATURE OF THE DISPUTE, CLAIM OR CONTROVERSY, SHE INTENDS FOR THE SUBMISSION OF THIS AGREEMENT TO THE PRESIDING JUDICIAL OFFICER TO BE A COMPLETE AND SUFFICIENT BASIS FOR THE IMMEDIATE DISMISSAL OF ANY AND ALL SUCH PROCEEDINGS WITH PREJUDICE TO FURTHER PROCEEDINGS OF ANY KIND. 6. Covenants, CH covenants, agrees, and promises that: A. CH will never disclose any non-public information, data, or knowledge she has leaned or will leam about the organization of RTC, CSI, or any other entity affiliated with the Scientology religion, or any persons associated with any such entity, including, but not limited (o, information or data rclated to their internal structures, security systems, finances, fimnctions, confidential locations oractivities, memos, correspondence, electronic information and information related to their schedules, duties and activities. CH acknowledges that disclosure of such information could cause irreparable injury to the Releasees and that the obligations set forth in this subparagraph will remain in force in perpetuity. B. CH will never disclose any information, data, or knowledge she has learned or will leam about or relating to any of the Releasees, their staff or former staff, officers or former officers, directors or former directors, trustees or former trustees, parishioners or former parishioners, or L. Ron Hubbard ‘that has not been authorized for release to the general public, Such matters include, by way of example and not limitation, information, data, or knowledge relating to security matters, financial information, private information concerning any of the Releases or their staff, including their schedules and activities, priest-penitent privileged communications, attomey-client privileged information, plans, programs, strategies, projects, or any other information about any of the Releasees or the Scientology religion, which are not specifically authorized to be disclosed by CH. CH acknowledges that disclosure of such information could cause irreparable injury to the Releasecs and that the obligations set forth in this subparagraph will remain in force in perpetuity. C. CH will never sell, copy, quote from, publish, electronically post, distribute, disseminate, duplicate, paraphrase, or reveal the contents of any of those Scientology materials known as the "Advanced Technology” or "Upper Level Materials." She acknowledges that the Upper Level Materials are confidential and that meticulous efforts are made to maintain that confidentiality. CH further represents that she does not have in her possession, custody, or control any such materials or copies thereof. CH acknowledges that disclosure of such information could cause irreparable injury to the Releases and that the obligations set forth in this subparagraph will remain in force in perpetuity. D. CH will never voluntarily assist any person, group or organization in any effort to harass or injure any of the Releasees, their staff, public or parishioners, and will not voluntarily assist in any ‘manner any person or entity involved in or contemplating investigation, litigation, or arbitration against any of the Releasees, whether as a plaintiff or as a defendant, unless compelled to do so by proper, non- collusive service of a subpoena or other lawful process upon CH. CH acknowledges that the obligations set forth in this subparagraph will remain in force in perpetuity. E. CH agrees never to create or electronically post or publish or attempt to publish, and/or assist another to create for publication or posting by means of newspaper story, magazine, article, book of other similar form, any writing, or to broadcast, of to assist another to create, write, film or video tape or audio tape, electronic posting, any news program, show, program or movie, concerning her experiences with, knowledge of, or information concerning, the Scientology religion, or any of the Releases, or any of their respective staff, former staff, parishioners, or former parishioners. CH acknowledges that the obligations set forth in this subparagraph will remain in force in perpetuity. F. CH willl never aid or assist in any manner any person or organization hostile o or engaged in attacks against the Scientology religion, any of its parishioners, or any of the Releasecs. CH acknowledges that the obligations set forth in this subparagraph will remain in force in perpetuity. OeG. CH will never testify or otherwise participate in any other judicial, administrative or legislative proceeding adverse to the Scientology religion, any of its parishioners, or any of the Releases, unless compelled to do so by proper, non-coltusive service of a subpoena or other lawful process. To enable RTC to assist CH should CH be served with such a subpoena or other process by a third party secking testimony and/or the production of documents conceming any of the Releasees, CH shall notify RTC through its corporate secretary or any ofits officers within two (2) days of receipt of such service, and shall furnish him or her with a copy of any such subpoena or process. CH acknowledges that the foregoing notice provision exists to help her to cooperate with RTC with respect to such subpoena and process. CH acknowledges that the obligations set forth in this subparagraph ‘will remain in foree in perpetuity H. CH agrees never to utter, write, print, post, disseminate, circulate, quote or published any kind of statement in any form, which are defamatory or disparaging, against any of the Releasees, ither directly or indirectly. CH acknowledges that the obligations set forth inthis subparagraph will remain in force in perpetuity. 7. Remedies for Breach. A. Cl agrees to resolve any dispute with any of the Releases through binding Scientology ecclesiastical arbitration under the authority of the Intemational Justice Chief. CH agrees that prior to her filing of any request for arbitration, she will endeavor to meet in person with a representative of RTC and exhaust all reasonable potential compromises and resolutions of such dispute. B. Should CH breach or threaten to breach this Agreement, she agrees that RTC or any other of the Releasees shall have the right to seek an ex parte issuance of a temporary restraining order, and to ‘obtain a preliminary and permanent injunction against her, without bond, in any court of competent jurisdiction, to prohibit her from breaching this Agreement and to compel her to comply with the terms of this Agreement. If RTC or any of the other Releasees have to take such legal action because CH threatens or attempts to or CH violates the terms of this Agreement, then she will be responsible for all costs, attorneys’ fees and damages arising from such action . No delay or omission of RTC or any other Releasee, in exercising any right or remedy accruing upon any default or breach of this Agreement shall be construed as a waiver of any such default or breach or any acquiescence therein. Every right and remedy conferred hereunder upon RTC, or any other Releasee may be enforced and exercised as often as permitted by law. 8. Severability. Ifany provision of this Agreement shall be declared to be void, invalid or otherwise unenforceable in whole or in part by a court of competent jurisdiction, all remaining provisions shall be unaffected and shall remain in full force and effect 9. Amendment.‘This Agreement may only be amended by written agreement signed byCH and RTC. 10. Applicable Law. ‘This Agreement shail be construed, interpreted, governed, and enforced in accordance with the laws of the State of California without reference to conflicts of law. 11, Consult with Counsel, ‘CH warrants that she has read and fully understands the nature and content of this Agreement. CH expressly acknowledges that she is entering into this Agreement freely and voluntarily and that she has had the opportunity to consult with counsel of her choice prior to the execution of this Agreement. CH further agrees to forbear and refrain from doing any act or exercising any right, whether existing now or in the future, which actor exercise is inconsistent with this Agreement. 13. Headings. ‘The paragraph headings contained in this Agreement are for convenience of reference only and shall not affect the construction of any provision of this Agreement. 14, Counterparts, ‘This Agreement may be executed in two or more counterparts, each of which will be deemed an original but all of which together shall constitute one and the same instrument. 15. Non-Parties to this Agreement, To the extent that this agreement inures to the benefit of persons or entities not signatories hereto, this Agreement is hereby declared to be made for their respective benefits and uses. 16. Additional Acts. CH and RTC will perform all further acts that may be reasonably necessary and useful 10 effectuate the purposes and provisions of this Agreement 17, Joint Preparation, Both CH and RTC have cooperated in the drafting and preparation of this Agreement. in any construction or interpretation to be made of this Agreement, it shall not be constcued against either CH or RTC. 2,18. No Assignment of Claims. Both CH and RTC acknowledge and warrant that she or it has not assigned or otherwise transferred to any third party an interest in any claim it may have against any signatory to this Agreement or Releasee, and CH acknowledges and agrees to indemnify and hold RTC and the Releasees harmless from any liability resulting from having assigned or transferred such interest to @ third party. 19. No Admissions. This Agreement is the document by which all rights, duties, and obligations of CH and RTC are ‘memorialized at the conclusion of CH’s employment by RTC. {t shall not in any way be construed as an admission by RTC that it acted wrongfully with respect to CH or any other person, or that CH has any rights whatsoever against RTC. RTC specifically disclaims and CH specifically acknowledges that RTC disclaims any liability to or wrongful acts against CH or any other person, on the part of itself, its agents, or anyone else acting on its behalf. 20. No Other Claims. CCH covenants and represents that she has not filed any complaints or charges or lawsuits against RTC or any Releasee with any governmental agency or any court, and thatCH will not do so at any time hereafter. 21. No Obligation, CH agrees and acknowledges that the consideration identified in paragraph 4 of this Agreement is not required to be given to CH by any policy or procedure of RTC. IN WITNESS WHEREOF, the parties have executed this Agreement on the date first written above. RELIGIOUS TECHNOLOGY CENTER: Warren MeShane President Claire HeadleyEXHIBIT ATO AGREEMENT AND GENERAL RELEASE CONFIDENTIAL INFORMATION is defined as information which has not been authorized to bbe published or revealed either to general Church of Scientology public or staff or in general. This includes but is not limited to the following: ‘A. Church issues with limited distributions, or information concerning them; B. Information relating to security of information or confidential Church premises and locations; C. Personal information regarding Church, RTC, or RTC staff or executives and their schedules and activities and private counseling, including auditing or use of the Scientology ethics technology, that has not been authorized by the individual himself or herself to be published; D. Expansion plans or programs of RTC that have not yet been released to general Church of Scientology staff or public; E. Any informnation which is considered by RTC or RTC to be trade secret, including but not limited (0 any and all Advanced Courses materials; F. Any information which relates to subjects conceming proprietary rights of RTC or Churches of Scientology, such as any copyrights, trademarks and trade secrets; G. Any information which relates to computer programming, design and user support for RTC or RTC or other Churches of Scientology; H. Any other information obtained through activities on behalf of RTC or RTC or any Church of Scientology, which relate to the operations or activities of the Church, RTC or any Church of Scientology, whether or not formally designated as “Confidential” which may not be generally known by or available to, the public or which, if disclosed, would tend to injure ot otherwise adversely affect RTC, the Church of Scientology or any of their respective a , functions, plans, programs or personnel. To the extent there is any question about the confidential status of any such matter, itis incumbent upon the party to this Agreement to verify this with a qualified RTC or RTC staff member before making any use or disclosure of it in any fashion.‘RON-DISCLOSURE AND RELEASR BOND , is held and now All Men by These Presents, that, oF (hereinafter called the "obligor firmly Bound to the Church of scientology International, ‘(hereinafter called the “church"), a corporation organized and existing under the laws of the State of California, and having. its principal place of business at 6331 Hollywood Blvd, Los Angeles, State of California, in the sum of Five Hundred Thousand Dollars ($500,000), to be paid to the said church, its executors, administrators, or assigns, as liquidated damages and not as a penalty, for the payment of which sum, well and truly to be made, the Obligor hereby binds himself, his heirs, executors, administrators and assigns firmly by these presents. WHEREAS the Church has hired or otherwise employed said obligor AND WHEREAS, Obligor is employed by the Church and is receiving the services and ministrations of the Church. AND WHEREAS, the Obligor wishes to remain in the service of the church and wishes to continue receiving compensation for work rendered by him/her in the service of the Church. NOW THEREFORE, the above written obligation is conditioned to be void in case the obligor shall hereafter well and truly agree that he/she will never disclose any information, data or knowledge he/she the has or will learn about the organization of the Church, or any of the church's affiliated churches, Missions or Organizations, including but not limited to their internal structures, functions or activities, and information which has been orally imparted to the Obligor in the course of his/her having been or being a staff member of the Church. The Obligor recognizes that any information or knowledge gathered is done so ina relationship of trust and confidence. ‘The obligor recognizes that he/she will have a fiduciary duty to the church not to reveal any information of any nature which might tend to ham, malign, damage, or injure or adversely affect the church in any of its activities or conduct. Inasmuch as the actual damages, which would result from a breach of the Obligor of his/her duties under this agreement, are uncertain and would be inpractical or extrenely difficult to fix, the obligor promises to pay to the Church the above mentioned sum of $500,000 for EACH such breach. This obligation shall inure to the benefit of and shall be binding upon the parties hereto, their successors, assigns, personal representatives, heirs and legatees. In the event of litigation te enforce the provisions of this Bond, the parties hereto agree that the prevailing party shall be entitled to recover reasonable attorney's sand other costs7 Mie A. Bere f co tiereny uence tae gaen oe Scientology, through its duly authorized personnel to receive, read and review any incoming mail addressed to me. I further authorize the above said Church representative to review my outgoing mail. 1 fully understand and am in agreement with the above realizing the importance of the maintenance of Security in the area I am currently working. Of my own free will I waive any rights or provisions to which I am entitled to under the privacy act. SIGNED: bese ve WITNESS FOR THE CHURCH OF SCIENTOLOGY:DECLARATION AND AGREEMENT OF NONDISCLOSURE By signing this Declaration and Agreement of Nondisclosure, |, CLAIRE HEADLEY, declare and agree as follows I was employed by RELIGIOUS TECHNOLOGY CENTER (“RTC”) and have now entered into the employ of Church of Scientology Intemational (“CST’) where I am. receiving the services and ministrations 2. Tenter into this Declaration and Agreement of Nondisclosure as consideration for receiving such services and ministrations, as I wish to remain in the employment of CSI and to continue to rect /e services and ministrations. I declare that I am not here to harm, malign, damage, injure or otherwise adversely affect the RTC, CSI or any of their activities, functions or personnel or affiliated organizations. I understand that my employment is dependent upon my honesty and my performance of the terms of this Declaration and Agreement of Nondisclosure (“Agreement”), 3. As aconsequence of my past employment with RTC and my current employment in CSI, Thad and have access to and have become ot will become acquainted with specialized confidential religious compilations of and communication conceming RTC, CSI and their products, projects, designs, plans, processes, management systems, organization functions, structures, residences and activities; information regarding L. Ron Hubbard, David Miscavige, or any executive and staff of RTC or CSI or its affiliated organizations; financial, and ecclesiastical, devices and inventions, in oral and written form, which are owned by and which are regularly used by RTC, or CSI or any of the Church's affiliated organizations (collectively “Confidential Information”) 42 4, Tacknowledge that any Confidential Information acquired by me during my employment with RTC or CSI is the property of RTC or CSI respectively or one 1ofits affiliated organizations and I pledge and agree never to disclose, reveal, imply or otherwise communicate, verbally or in writing, to any person not authorized by the CSI or RTC to receive the information. My purpose in signing this Agreement is to protect the CSI and RTC and their employees and all their affiliated organizations from the disclosure of Confidential Information. Further, I recognize that | have a fiduciary duty to CSI and RTC not to reveal the Confidential Information. 5, Tagree that any Confidential Information acquired by me, in written or tangible form may not be removed from RTC or CSI premises for any purpose without prior written approval by RTC or CSI. Upon termination of my employment, all such Confidential Information must be returned to the custody of RTC or CSI and I may not make, take or retain any copies thereof in any form or medium. 6. Tunderstand and agree that it would be impractical or extremely difficult to fix actual damages that would result fiom a breach of this Declaration and Agreement of Nondisclosure. Therefore, I agree to pay to RTC and/or CSI as applicable, as liquidated ‘damages and not as a penalty, the sum of Seventy Five Thousand Dollars (75,000.00) for each breach of this Agreement. I understand that this sum represents a reasonable attempt to estimate a fair compensation for the foreseeable losses that might result from such a breach. This provision for liquidated damages shall not preclude RTC or CSI from electing to pursue any of the other legal or equitable remedies thal may be available to them 7. agree that in the event my employment with CSI is terminated for any reason whatsoever, I am obliged to and will continue to uphold the promises made herein not to disclose any Confidential Information which I acquired during my employment with either RTC onGS1 as long as I shall ive SS 8. Inthe event any provision of this Agreement is declared to be void, invalid orunenforceable for any reason by a court of competent jurisdiction, I agree that every other provision of this Agreement shall remain valid and enforceable in full. 9, Tunderstand and agree that in the event RTC or CSI initiates an action to enforce this Declaration and Agreement of Nondisclosure, and is successful in enforcing its terms as to any material breach, I will be liable for all attorney's fees and court costs incurred by RTC or CSI in connection therewith ‘This Agreement shall be interpreted under the laws of the State of California. Dated 8 Sept Of Witness SUBSCRIBED AND SWORN before me this 13 day of September 2004. ae] ae conten? tat Kh & bo) 3 sitaynate camara £ te ago Cover Notaky Public 4 mycin ro nf> e © rercartnsercam nie tats 382) PROOF OF SERVICE 5822 2 || STATE OF CALIFORNIA, COUNTY OF LOS ANGELES ) ghey 3 I am employed in the County of Los Angeles, State of California gene I am over the age of 18 years and am not a party to the within action. My $i! 4 || business address is 401 East Ocean Blvd., #800, Long Beach, CA 90802. ays bets on February 2, 2010, I served the foregoing document, described Fe || a8: SUMMONS ON SECOND ANENDED ‘COMPLAINT; SECOND AMENDED COMPLAINT on the 6 || parties to this action as follows: 1 X_ (BY MAIL) I caused copies of such document, enclosed in sealed envelopes, to be deposited in the mail at Long Beach, California 8 || with postage thereon fully prepaid to the persons and addresses indicated Jon the attached list, I am "readily familiar" with the firm's practice of 9 || collecting and processing correspondence for mailing. It is deposited with U.S. Postal Service on that same day in the ordinary course of business. > 10 || 1_am aware that on motion of any party served, service is presumed invalid 283 if the postal cancellation date or postage meter date is more than one day e211 || after the date of deposit for mailing set forth in this affidavit. ees wees 12 (BY FACSIMILE) I served the foregoing document by faxing SNEES true copies thereof from facsimile number (562} 436-1561, to the facsimile ONG Es : gu,&z'3 |) numbers indicated on the attached list. Said document was transmitted by oees5 facsimile transmission, which was reported complete and without error. Bags pee25 (BY PERSONAL SERVICE) I caused to be delivered such 3285215 || document by hand to the firms listed on the attached list where personal giog service is indicated. Tepe 16 fog ____ (BY E-MAIL) I delivered such document by electronic mail

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