SAC - Revised

F:\WP\Cases\9527\PLEADDOC\COMPLAIN\SAC - Revised.
wpd
1 BARRY VAN SICKLE, ESQ., SBN 98645

1079 SUNRISE AVENUE, SUITE B-315
2 ROSEVILLE, CA 95661
TELEPHONE: (916) 549-8784
3 EMAIL: barryvansickle@comcast.net
4 METZGER LAW GROUP
A PROFESSIONAL LAW CORPORATION
5 RAPHAEL METZGER, ESQ., SBN 116020
401 E. OCEAN BLVD., SUITE 800
6 LONG BEACH, CA 90802-4966
TELEPHONE: (562) 437-4499
7 TELECOPIER: (562) 436-1561
8 Attorneys for Plaintiff
Laura Ann DeCrescenzo
9
10 SUPERIOR COURT OF THE STATE OF CALIFORNIA
11 FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
12
13 LAURA ANN DeCRESCENZO, aka ) CASE NO. BC411018
LAURA A. DIECKMAN, ) Assigned to the Honorable
14 ) Ronald M. Sohigian, Dept. 41
Plaintiffs, )
15 ) SECOND AMENDED COMPLAINT
vs. ) ASSERTING CAUSES OF ACTION FOR:
16 )
CHURCH OF SCIENTOLOGY ) (1) FORCED ABORTION IN
17 INTERNATIONAL, a corporate ) VIOLATION OF ARTICLE I,
entity, RELIGIOUS TECHNOLOGY ) SECTION 1 OF THE
18 CENTER, previously sued herein ) CALIFORNIA CONSTITUTION;
as Doe No. 1, a California ) (2) FORCED ABORTION IN
19 corporation, AND DOES 2 - 20, ) VIOLATION OF COMMON LAW;
) (3) DEPRIVATION OF LIBERTY IN
20 Defendants. ) VIOLATION OF ARTICLE I,
_______________________________ ) SECTION 1 OF THE
21 CALIFORNIA CONSTITUTION;
(4) FALSE IMPRISONMENT;
22 (5) INTENTIONAL INFLICTION OF
EMOTIONAL DISTRESS;
23 (6) VIOLATION OF LABOR CODE
§§ 970 AND 1194; AND
24 (7) VIOLATION OF BUSINESS &
PROFESSIONS CODE § 17200
25
DEMAND FOR JURY TRIAL [MADE
26 PURSUANT TO CALIFORNIA CODE O
CIVIL PROCEDURE §§ 600 ET SEQ.
27 AND PURSUANT TO RULE 38 OF THE
FEDERAL RULES OF CIVIL
28 PROCEDURE SHOULD THIS CASE EVER
BE REMOVED TO FEDERAL COURT]
SECOND AMENDED COMPLAINT

F:\WP\Cases\9527\PLEADDOC\COMPLAIN\SAC - Revised.wpd
1 Plaintiff, Laura Ann DeCrescenzo, hereby alleges:

2
3 THE PARTIES
4
5 1. At all material times hereto, Plaintiff, Laura Ann
6 DeCrescenzo, resided and worked in the State of California.
7 2. Plaintiff is informed and believes and thereon alleges
8 that Defendant, Church of Scientology International (“CSI”), is a
9 California corporation, which at all material times hereto, was doing
10 business in the County of Los Angeles, State of California.
11 3. Plaintiff is informed and believes and thereon alleges
12 that Defendant, Religious Technology Center (“RTC”), previously sued
13 herein as Doe No. 1, is a California corporation, which at all
14 material times hereto, was doing business in the County of Los
15 Angeles, State of California.
16 4. The true names and capacities of Defendants Does 2
17 through 20 are unknown to Plaintiff, who therefore sues said
18 defendants by such fictitious names. Plaintiff will amend this
19 complaint to state the true names and capacities of said fictitious
20 defendants when they have been ascertained. Plaintiff is informed
21 and believes and thereon alleges that Defendants Does 2 through 20
22 are in some manner responsible for the occurrences herein alleged,
23 and that Plaintiff’s damages as herein alleged were proximately
24 caused by their conduct.
25 //
26 //
27 //
28 //
2

1 GENERAL ALLEGATIONS
2
3 5. From approximately 1991 to 2004, Plaintiff was
4 employed by Defendant, CSI. During this time, Plaintiff worked and
5 lived at Defendant, CSI’s facilities located in Los Angeles,
6 California. Plaintiff started working for Defendant, CSI, at age
7 twelve and continued working for Defendant, CSI, until age twenty-
8 five. As alleged in detail below, during Plaintiff’s employment,
9 Defendant, CSI, deprived Plaintiff of her rights to privacy and
10 liberty, intentionally caused Plaintiff severe emotional distress,
11 and failed to pay Plaintiff minimum wage or post required wage
12 orders.
13 6. Plaintiff also worked for Defendant, RTC. Defendant,
14 RTC, was responsible for and directly oversaw a number of the
15 policies and conditions of Plaintiff’s employment. Moreover, one or
16 more top RTC executives were actively involved in drafting and using
17 bogus forms, releases, and purported contracts to scare and
18 intimidate its employees, including Plaintiff, even though Defendant,
19 RTC, knew that said forms and waivers were unenforceable and contrary
20 to law.
21 //
22 //
23 //
24 //
25 //
26 //
27 //
28 //
3

1 FIRST CAUSE OF ACTION

2 FOR FORCED ABORTION IN VIOLATION OF PLAINTIFF’S RIGHT OF PRIVACY
3 UNDER ARTICLE I, SECTION 1 OF THE CALIFORNIA CONSTITUTION
4 (By Plaintiff, Laura Ann DeCrescenzo,
5 Against All Named Defendants and Does 2-20)
6
7 7. During Plaintiff’s employment with Defendants, she
8 became pregnant on one occasion in approximately 1996. Plaintiff was
9 seventeen years old at the time she became pregnant.
10 8. Defendants forced Plaintiff to have an abortion by
11 threatening Plaintiff with losing her job, housing, and losing her
12 husband if she did not have an abortion. Further, Defendants
13 threatened that upon losing her job, Plaintiff would owe Defendants
14 a “Freeloader Debt,” which is a supposed debt that Plaintiff would
15 owe Defendants for purported Scientology training and services.
16 Plaintiff was subjected to these threats for two days straight.
17 9. At all material times hereto, Defendants have had an
18 internal policy of coercing and forcing their female employees,
19 including Plaintiff, to have abortions, so as to maximize the
20 workload from female employees and to avoid child care issues.
21 10. As a direct and proximate result of Defendants’
22 coercion and threats of terminating Plaintiff’s job, threats that
23 Plaintiff would never again see her husband, and threats that
24 Plaintiff would incur a substantial debt, Plaintiff had an abortion
25 in approximately 1996.
26 11. Plaintiff had a reasonable expectation of privacy in
27 deciding whether to continue her pregnancy or to have an abortion.
28 A woman’s right of privacy in deciding whether or not to bear
4

1 children is one of the most intimate and fundamental of all

2 constitutional rights because it follows from repeated
3 acknowledgments of the Supreme Court and other courts of this State
4 of a right to privacy in matters related to marriage, family, and
5 sex.
6 12. Defendants invaded Plaintiff’s right of privacy in
7 deciding whether to continue her pregnancy or to have an abortion by
8 forcing Plaintiff to have an abortion or risk losing her job and
9 housing, risk never seeing her husband again, and risk incurring a
10 substantial debt.
11 13. Defendants’ conduct in forcing Plaintiff to have an
12 abortion was a serious invasion of Plaintiff’s privacy because it
13 stripped Plaintiff of one of the most intimate and fundamental of all
14 constitutional rights, which is a woman’s right to privacy in
15 deciding whether or not to bear children. It is well-established
16 that this right of personal choice is central to a woman’s control
17 not only of her own body, but also to the control of her social role
18 and personal destiny. Particularly in the workplace, a woman has a
19 heightened right of privacy in deciding whether or not to bear
20 children.
21 14. As a direct and proximate result of Defendant’s
22 conduct in forcing Plaintiff to have an abortion or risk losing her
23 job and housing, risk losing her husband, and risk incurring a
24 substantial debt, Plaintiff suffers from severe emotional distress,
25 including anxiety, embarrassment, humiliation, shame, depression,
26 feelings of powerlessness, and anguish.
27 //
28 //
5


2 abortion or risk losing her job and housing, risk losing her husband,
3 and risk incurring a significant debt, was a substantial factor in
4 causing Plaintiff’s severe emotional distress.
5 16. Plaintiff seeks damages for her emotional distress in
6 a sum to be established according to proof. Further, Plaintiff seeks
7 an injunction against forced abortions in violation of the right to
8 privacy and reasonable attorney's fees according to proof. This
9 claim is made for the public good and to discourage this outrageous
10 conduct from continuing in the future.
11 17. From approximately 1996 to 2004, Plaintiff could not
12 reasonably have discovered that she had a claim for forced abortion
13 in violation of her constitutional right of privacy because Plaintiff
14 was enmeshed in a confidential relationship with Defendants and was
15 brainwashed by Defendants such that she had no comprehension of her
16 legal rights. The confidential relationship that existed between
17 Plaintiff and Defendants, as well as the brainwashing to which
18 Plaintiff was subjected, are demonstrated by the following:
19 (A) Plaintiff was recruited by Defendants when she
20 was the tender age of nine while living in New Mexico, and moved away
21 from her family to live and work at Defendants’ facilities in
22 California when she was a mere twelve years old. During Defendants’
23 recruitment of Plaintiff, Plaintiff was led to believe that her life
24 at Defendants’ facilities would remain relatively normal -
25 specifically, Plaintiff believed that she would continue to get an
26 education, that she would be allowed to visit her parents with ease,
27 and that one day, she could have children and a family of her own.
28 Plaintiff also believed that she would receive training in
6

1 Scientology and would be allowed to move “up the bridge” of

2 Scientology. Plaintiff therefore signed a "billion year contract"
3 with Defendants at age twelve.
4 (B) Once Plaintiff began living at Defendants’
5 facilities, Defendants severely restricted Plaintiff’s access to the
6 outside world. Plaintiff had limited and restricted access to email,
7 telephones, the internet, or uncensored television. Defendants also
8 opened, read, and censored all mail.
9 (C) Even Plaintiff’s access to her parents was
10 restricted, as Plaintiff only was allowed to leave Defendants’
11 facilities upon receiving special permission from Defendants, which
12 rarely was granted. Each time before Plaintiff left Defendants’
13 facilities and each time before Plaintiff returned to Defendants’
14 facilities, she was required to undergo a security checking procedure
15 (known as a “sec check”). During a sec check, Plaintiff was, among
16 other things, interrogated by Defendants using a primitive lie
17 detector known as an “e-meter.” The information that Plaintiff
18 disclosed during these interrogations was documented by written means
19 and/or recorded by video or audio means. Sec checks are used to
20 gather and record confidential and embarrassing information, and to
21 wear a worker’s resistance down by hours of repetitive and intrusive
22 questioning. Plaintiff was subjected to sec checks on numerous other
23 occasions during her employment with Defendants as well, as
24 Defendants deemed appropriate.
25 //
26 //
27 //
28 //
7

1 (D) Plaintiff had little formal education or

2 sophistication. At the time Plaintiff began living at Defendants’
3 facilities, she had only a seventh grade education, and contrary to
4 Defendants’ representations, Plaintiff received no formal education
5 while living at Defendants’ facilities.
6 (E) Plaintiff was entirely dependent on Defendants
7 for her sustenance, shelter, and income.
8 (F) Defendants commanded a rigid work schedule from
9 Plaintiff; Plaintiff worked seven days a week, often for 100 or more
10 hours, at below minimum wage. During Plaintiff’s entire employment
11 with Defendants, Plaintiff routinely and consistently was deprived
12 of her sleep and required to stay up for days on end.
13 (G) To punish Plaintiff for various purported wrongs
14 during her employment, Defendants sent Plaintiff to the
15 Rehabilitation Project Force ("RPF") where Defendants forced
16 Plaintiff to work under harsh conditions and perform manual labor.
17 At the RPF, Plaintiff also was not allowed to leave without special
18 permission, had no freedom of movement, was almost constantly under
19 guard and being watched, and was subjected to near total deprivation
20 of personal liberties. Plaintiff was confined to the RPF for several
21 years of her employment.
22 (H) Defendants forbade Plaintiff from reading or
23 thinking anything negative about the Church of Scientology. This was
24 enforced through the isolation tactics detailed above, as well as
25 through the constant threat of sec checks and other forms of
26 punishment, such as the RPF.
27 //
28 //
8

1 (I) Plaintiff spent the entirety of her formative

2 years at Defendants’ facilities, from age twelve to age twenty-five,
3 and was isolated from mainstream society during this entire period.
4 (J) During her thirteen years at Defendants’ various
5 facilities (from age twelve to age twenty-five), Plaintiff’s female
6 co-workers regularly were ordered by Defendants to have abortions,
7 and Plaintiff believed these abortions and Defendants’ ordering of
8 these abortions were standard protocol.
9 18. In 2004, Plaintiff learned that after years of work
10 in the RPF and after completing all of the tasks required of her to
11 be released from the RPF multiple times over, Plaintiff would not be
12 allowed to leave the RPF. Broken and fearful of a continued stay in
13 the RPF, Plaintiff could no longer tolerate living and working at
14 Defendants’ facilities and determined that she had to escape. To get
15 out of Defendants’ facilities and end her employment, Plaintiff faked
16 suicide.
17 19. Upon learning of Plaintiff’s suicidal actions,
18 Defendants agreed that Plaintiff could leave their facilities and end
19 her employment. However, before Plaintiff could leave Defendants’
20 facilities in 2004, Plaintiff was required to sign certain documents.
21 Defendants represented to Plaintiff that by signing these documents,
22 Plaintiff released any and all claims she had against Defendants and
23 that these documents required Plaintiff to keep certain information
24 “confidential,” and that if Plaintiff did not keep this information
25 “confidential,” she would be subject to paying significant
26 penalties/fines. Defendants knew at the time that Plaintiff signed
27 these documents that they were unenforceable and contrary to law.
28 However, Defendants regularly use these types of forms and documents
9

1 to scare and intimidate their employees into believing that they have
2 no legal rights against Defendants, and intended that Plaintiff would
3 rely on these documents in that fashion.
4 20. Plaintiff believed she would not be allowed to leave
5 Defendants’ facilities in 2004 unless she signed these documents, and
6 further believed that she had given up any and all claims she had
7 against Defendants by signing these documents (even though she
8 remained unaware of these claims at that time). Plaintiff was never
9 given copies of the documents that she signed. However, attached as
10 Exhibit “A” are a true and correct copies of documents signed by
11 individuals similarly situated to Plaintiff, which Plaintiff is
12 informed and believes and thereon alleges are reasonably similar to
13 the documents that Plaintiff was coerced into signing by Defendants
14 upon leaving their facilities.
15 21. From approximately 2004 to July 2008, Plaintiff, to
16 her detriment, reasonably believed that she did not have any legal
17 rights or claims against Defendants because of the documents that she
18 signed upon leaving Defendants’ facilities and because of Defendants’
19 representations with respect to said documents. During this time,
20 2004 to 2008, Plaintiff remained a loyal follower of the Church of
21 Scientology. As a follower, Plaintiff was forbidden from reading or
22 thinking anything negative about Scientology. Further, Plaintiff was
23 threatened with rigorous sec checks, and was threatened with being
24 deemed a "Suppressive Person" if she in any way was perceived to be
25 an enemy of Scientology. As a "Suppressive Person," Plaintiff would
26 have been forbidden contact with her friends and family who remained
27 at Defendants’ facilities and who continued practicing Scientology,
28 and would have been subjected to harassment by Defendants. Indeed,
10

1 when Plaintiff left Defendants’ facilities in 2004, she was informed

2 that she owed Defendant, CSI, approximately $120,000 for her
3 on-the-job training since age twelve; this is commonly referred to
4 by the Church of Scientology as a “Freedloader Debt.” Plaintiff
5 continued paying this purported “Freeloader Debt” well after leaving
6 Defendants’ facilities in 2004 based upon her genuine belief in
7 Defendants’ representations regarding her legal rights and
8 obligations. Moreover, Plaintiff continued to purchase the Church
9 of Scientology’s literature and assisted local missions in collecting
10 “donations” for the Church of Scientology.
11 22. In approximately July 2008, when using a family
12 member’s computer, Plaintiff discovered a web page minimized on the
13 screen that appeared to be an “Ex-Scientologist” message board.
14 Plaintiff confronted her family member regarding this page, as she
15 and her family members were forbidden by the Church of Scientology
16 from reading or thinking anything negative about Scientology.
17 Initially, her family member explained that this page was simply
18 stumbled across by accident. However, within days, Plaintiff’s
19 relatives sat her down to explain that they disagreed with a number
20 of things that had happened in Scientology and that happened to
21 Plaintiff while she was living at Defendants’ facilities. These
22 family members then showed Plaintiff a number of internet message
23 boards, where Plaintiff discovered the stories of friends who had
24 lived and worked at the same facilities of Defendants as Plaintiff.
25 //
26 //
27 //
28 //
11

1 It was only after listening to the concerns of her family members and
2 reading the stories of her friends in July 2008 that Plaintiff
3 realized that she might have legal claims against Defendants and that
4 the documents and “confidentiality” agreements she was coerced into
5 signing by Defendants in 2004 were potentially invalid.
6
7 SECOND CAUSE OF ACTION
8 FOR FORCED ABORTION IN VIOLATION OF PLAINTIFF’S
9 RIGHT OF PRIVACY UNDER CALIFORNIA COMMON LAW
12
13 23. During Plaintiff’s employment with Defendants, she
14 became pregnant on one occasion in approximately 1996. Plaintiff was
15 seventeen years old at the time she became pregnant.
16 24. Defendants forced Plaintiff to have an abortion by
17 threatening Plaintiff with losing her job, housing, and losing her
18 husband if she did not have an abortion. Further, Defendants
19 threatened that upon losing her job, Plaintiff would owe Defendants
20 a “Freeloader Debt,” which is a supposed debt that Plaintiff would
21 owe Defendants for purported Scientology training and services.
22 Plaintiff was subjected to these threats for two days straight.
23 25. Defendants have an internal policy of forcing and
24 coercing their female employees, including Plaintiff, to have
25 abortions, so as to maximize the workload from female employees and
26 to avoid child care issues.
27 //
28 //
12


2 coercion and threats of terminating Plaintiff’s job, threats that
3 Plaintiff lose her housing, threats that Plaintiff would never again
4 see her husband, and threats that Plaintiff would incur a substantial
5 debt, Plaintiff had an abortion in approximately 1996.
6 27. Plaintiff had a reasonable expectation of privacy in
7 deciding whether to continue her pregnancy or to have an abortion.
8 A woman’s right of privacy in deciding whether or not to bear
9 children is one of the most intimate and fundamental of all privacy
10 rights because it follows from repeated acknowledgments by the
11 Supreme Court and courts of this State of a right to privacy in
12 matters related to marriage, family, and sex.
13 28. Defendants intentionally intruded into Plaintiff’s
14 private affairs and concerns in deciding whether to continue her
15 pregnancy or have an abortion by ordering Plaintiff to have an
17 and risk incurring a substantial debt.
18 29. Defendants’ intrusion into Plaintiff’s private
19 decision of whether to continue her pregnancy or to have an abortion
20 would be highly offensive to a reasonable person. A woman’s right
21 of privacy in deciding whether or not to bear children is one of the
22 most intimate and fundamental of all privacy rights; this right is
23 central to a woman’s control not only of her own body, but also to
24 the control of her social role and personal destiny. Further, in the
25 workplace, there is a heightened sense and expectation of privacy as
26 to matters concerning family and sex.
27 //
28 //
13


2 conduct in forcing Plaintiff to have an abortion or risk losing her
3 job and housing, risk losing her husband, and risk incurring
4 substantial debt, Plaintiff suffers from severe emotional distress,
5 including anxiety, embarrassment, humiliation, shame, depression,
6 feelings of powerlessness, and anguish.
9 and risk incurring significant debt was a substantial factor in
12 a sum to be established according to proof.
14 reasonably have discovered that she had a claim for forced abortion
15 in violation of her common law right of privacy because Plaintiff was
16 enmeshed in a confidential relationship with Defendants and was
17 brainwashed by Defendants such that she had no comprehension of her
18 legal 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:
14

9 telephones, the internet, or uncensored television. Defendants
27 //
28 //
15


27 //
28 //
16


4 (J) During her thirteen years at Defendants’ various
5 facilities (from age twelve to age twenty-five), Plaintiff’s female
6 co-workers regularly were ordered by Defendants to have abortions,
7 and Plaintiff believed these abortions and Defendants’ ordering of
8 these abortions were standard protocol.
16 suicide.
17

18


26 //
27 //
28 //
19


5
6 THIRD CAUSE OF ACTION
7 FOR DEPRIVATION OF LIBERTY IN VIOLATION OF
8 ARTICLE I, SECTION 1 OF THE CALIFORNIA CONSTITUTION
11
12 39. From approximately July 2001 to April 2004, Defendants
13 interfered with Plaintiff’s constitutional right of liberty set forth
14 in Article I, Section 1 of the California Constitution by confining
15 Plaintiff to the Rehabilitation Project Force (“RPF”) by means of
16 threats, intimidation, and coercion.
17 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 Instead of allowing Plaintiff to leave, Defendants “handled”
22 Plaintiff and threatened that if she did not go to the RPF, Plaintiff
23 would lose her job and housing, Plaintiff would incur substantial
24 “Freeloader” debt, Plaintiff would no longer be able to associate
25 with any of her friends and co-workers at Defendants’ facilities, and
26 //
27 //
28 //
20

1 that Defendants would disclose embarrassing information about

2 Plaintiff that was obtained during sec checks. Defendants’ coercion
3 and repeated threats went on for a period of a week or more, at which
4 time, Plaintiff finally gave in and was transported to the RPF.
5 41. Once Plaintiff arrived at the RPF, she again decided
6 that she did not want to be there and asked to leave. Plaintiff was
7 not allowed to leave, and instead, Defendants made Plaintiff stay up
8 for hours on end, and threatened, intimidated, and coerced Plaintiff
9 into staying at the RPF. Defendants again threatened that Plaintiff
10 would lose her job and housing, incur substantial “Freeloader” debt,
11 Plaintiff would no longer be able to associate with any of her
12 friends and co-workers at Defendants’ facilities, and that Defendants
13 would disclose embarrassing information about Plaintiff that was
14 obtained during sec checks.
15 42. The RPF was brutal, and Plaintiff was forced to work
16 under harsh conditions and perform manual labor. Indeed, on at least
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 cycles. When and if Plaintiff traveled from building to building,
25 she was accompanied by a security guard or control group. When
26 Plaintiff used the phone, her conversations typically were monitored
27 by a security guard.
28 //
21

1 44. Plaintiff reasonably believed that if she exercised

2 her right of liberty and attempted to leave the RPF, Defendants would
3 retaliate against Plaintiff. Specifically, Plaintiff recalls having
4 to sign a bond with Defendants, whereby Plaintiff would owe
5 Defendants one million dollars or ten million dollars for “each
6 breach of security.” Moreover, given Defendants’ repeated threats,
7 Plaintiff reasonably believed that if she left the RPF, she would
8 lose her job and housing, incur substantial “Freeloader” debt, would
9 no longer be able to associate with any of her friends or co-workers
10 at Defendants’ facilities, and that Defendants would disclose
11 embarrassing information about Plaintiff that was obtained during her
12 sec checks. Plaintiff knew from experience that once someone left
13 Defendants’ facilities, she never again saw, heard from, or spoke to
14 those individuals.
16 interference with Plaintiff’s constitutional right of liberty whereby
17 Plaintiff was confined to the RPF for several years of her life as
18 a result of Defendants’ repeated threats, intimidation, and coercion,
19 Plaintiff suffers from severe emotional distress, including anxiety,
20 embarrassment, humiliation, shame, depression, feelings of
21 powerlessness, and anguish.
22 46. Defendants’ conduct in interfering with Plaintiff’s
23 constitutional right of liberty by means of threats, intimidation,
24 and coercion was a substantial factor in causing Plaintiff’s severe
25 emotional distress.
27 a sum to be established according to proof. Further, Plaintiff seeks
28 an injunction against future confinement and deprivation of liberty
22

1 by means of threats, coercion, and intimidation on the part of

2 Defendants, and reasonable attorney's fees according to proof. This
3 claim is made for the public good and to discourage this outrageous
4 conduct from continuing in the future.
12 suicide.
28 //
23


24


27 //
28 //
25

1 FOURTH CAUSE OF ACTION

2 FOR FALSE IMPRISONMENT
5
6 53. Between July 2001 and April 2004, Defendants
7 intentionally confined Plaintiff to the Rehabilitation Project Force
8 (“RPF”) by means of unreasonable duress.
9 54. In approximately July 2001, Plaintiff was informed
10 by Defendants that she was being sent to the RPF for having committed
11 purported wrongs. At that time, Plaintiff refused to go to the RPF
12 and informed Defendants that she wanted to leave their facilities.
13 Instead of allowing Plaintiff to leave, Defendants “handled”
14 Plaintiff and threatened that if she did not go to the RPF, Plaintiff
15 would lose her job and housing, Plaintiff would incur substantial
16 “Freeloader” debt, Plaintiff would no longer be able to associate
17 with any of her friends and co-workers at Defendants’ facilities, and
18 that Defendants would disclose embarrassing information about
19 Plaintiff that was obtained during sec checks. Defendants’ coercion
20 and repeated threats went on for a period of a week or more, at which
21 time, Plaintiff finally gave in and was transported to the RPF.
22 55. Once Plaintiff arrived at the RPF, she again decided
23 that she did not want to be there and asked to leave. Plaintiff was
24 not allowed to leave, and instead, Defendants made Plaintiff stay up
25 for hours on end, and threatened, intimidated, and coerced Plaintiff
26 into staying at the RPF. Defendants again threatened that Plaintiff
27 would lose her job and housing, incur substantial “Freeloader” debt,
28 Plaintiff would no longer be able to associate with any of her
26

1 friends and co-workers at Defendants’ facilities, and that Defendants

2 would disclose embarrassing information about Plaintiff that was
3 obtained during sec checks. Although Plaintiff thereafter remained
4 at the RPF, Plaintiff was not capable of, and did not, voluntarily
5 consent to her confinement at the RPF.
6 56. Plaintiff was watched almost constantly while at the
7 RPF. Indeed, Plaintiff was restricted to the building where the RPF
8 was located, and was only allowed outside the building on authorized
9 work cycles. When and if Plaintiff traveled from building to
10 building, she was accompanied by a security guard, and when Plaintiff
11 used the phone, her conversations were monitored by a security guard.
12 Plaintiff was not permitted to speak to anyone, unless spoken to
13 first.
15 intentional confinement of Plaintiff, Plaintiff suffers from severe
16 emotional distress, including anxiety, embarrassment, humiliation,
17 shame, depression, feelings of powerlessness, and anguish.
18 58. Defendants’ conduct of intentionally confining
19 Plaintiff to the RPF without her consent was a substantial factor in
27


2 suicide.
28


29


16
17 FIFTH CAUSE OF ACTION
18 FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
21
22 65. During Plaintiff’s employment with Defendants from
23 approximately 1991 to 2004, Defendants intended to cause Plaintiff
24 severe emotional distress.
25 //
26 //
27 //
28 //
30

1 66. Defendants’ conduct that was intended to cause

2 Plaintiff severe emotional distress includes Defendants’ repeated
3 interrogations of Plaintiff while performing purported “sec checks”
4 and Defendants’ supposed punishment and rehabilitation of Plaintiff
5 in the RPF.
6 67. As described in preceding paragraphs, security
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
11 risk. Employees such as Plaintiff are told, and come to believe,
12 that they can have no secrets from Defendants’ management. Any such
13 secrets or bad thoughts will be exposed in "sec checks" on the
14 e-meter. This process started for Plaintiff on or before her first
15 planned visit with her parents at age twelve and continued for her
16 thirteen years of working for Defendants.
17 68. The sec checks performed by Defendants on Plaintiff
18 were invasive, degrading, and abusive. Plaintiff was interrogated
19 by Defendants for hours, occasionally day after day, and was forced
20 and coerced into confessing embarrassing information. The
21 information that Plaintiff disclosed was then documented by written
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 //
28 //
31

1 69. As described in preceding paragraphs, Plaintiff also

2 was forced to spend several years of her employment with Defendants
3 in the RPF, from July 2001 to April 2004. In the RPF, Plaintiff was
4 forced to do manual labor and live under incredibly harsh conditions.
5 Indeed, on at least one occasion, Plaintiff was instructed to clean
6 a large trash dumpster with a toothbrush. When Plaintiff purportedly
7 acted out in the RPF, she was punished by being forced to run around
8 the basement of the building where the RPF was located or do push-
9 ups. In addition, Plaintiff's pay, which already was below minimum
10 wage, was docked by Defendants while she worked in the RPF.
11 70. Likewise, Plaintiff was watched almost constantly
12 while in the RPF. Plaintiff was restricted to the building where the
13 RPF was located, and was only allowed outside the building on
14 authorized work cycles. When and if Plaintiff traveled from building
15 to building, she was accompanied by a security guard, and when
16 Plaintiff used the phone, her conversations were monitored by a
17 security guard. Plaintiff was not permitted to speak to anyone,
18 unless spoken to first. This confinement and Defendants’ almost
19 constant watch over Plaintiff lasted for over two and half years of
20 the time that Plaintiff lived and worked at Defendants’ facilities.
21 71. Defendants’ conduct in subjecting Plaintiff to
22 lengthy, harassing, and degrading interrogations or “sec checks” was
23 outrageous and was in reckless disregard of the probability of
24 causing Plaintiff severe emotional distress. This conduct was
25 extreme and clearly exceeded the bounds of that usually tolerated in
26 civilized society. Indeed, this type of conduct is not tolerated
27 when used by police departments, let alone, when used by employers.
28 //
32

1 72. Defendants’ conduct in subjecting Plaintiff to years

2 of life in the RPF also was outrageous and was in reckless disregard
3 of the probability of causing Plaintiff severe emotional distress.
4 The tasks that Defendants mandated Plaintiff complete and Defendants’
5 confinement and isolation was Plaintiff was extreme and clearly
6 exceeded the bounds of that usually tolerated in civilized society.
8 outrageous conduct and reckless disregard, Plaintiff suffers from
9 severe emotional distress, including anxiety, embarrassment,
10 humiliation, shame, depression, feelings of powerlessness, and
11 anguish.
12 74. Defendants’ outrageous conduct and reckless disregard
13 for Plaintiff was a substantial factor in causing Plaintiff’s severe
14 emotional distress.
24 suicide.
33


34


35


10
11 SIXTH CAUSE OF ACTION
12 FOR VIOLATION OF WAGE AND HOUR LAWS SET FORTH IN
13 CALIFORNIA LABOR CODE SECTIONS 970 AND 1194
16
17 81. From approximately 1991 to 2004, Plaintiff performed
18 work for Defendants. Defendants, and each of them, controlled wages,
19 hours, and working conditions.
20 82. When Defendants solicited Plaintiff to work and live
21 at their facilities in approximately 1991, Defendants represented to
22 Plaintiff that Plaintiff would be paid for her work, that Plaintiff
23 would receive up to three weeks vacation per year, that Plaintiff
24 would be allowed to visit her parents once a month, that Plaintiff
25 would work hours consistent with being a minor, and that Plaintiff
26 would continue to get a formal education while working at Defendants’
27 facilities.
28 //
36

1 83. Defendants’ representations were not true. During

2 Plaintiff’s work for Defendants from 1991 to 2004, Plaintiff was
3 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
5 to her parents was severely restricted), Plaintiff routinely worked
6 seven days a week for 100 or more hours (which is not consistent with
7 the working hours of a minor), and Plaintiff did not receive any
8 formal education.
9 84. Defendants knew at the time that they made the
10 aforementioned representations to Plaintiff in 1991 that these
11 representations were not true. With respect to workers in
12 Plaintiff’s position, Defendants’ have an internal policy of limiting
13 and restricting vacation time, limiting workers’ access to their
14 parents and outside family, and of requiring these workers to
15 consistently work seven days a week for 100 or more hours. Moreover,
16 because Defendants command so many working hours of their employees
17 and do not have a formal education system, Defendants knew that
18 Plaintiff would not receive a formal education while under their
19 employ.
20 85. Defendants further intended that Plaintiff would rely
21 on their representations regarding Plaintiff’s working conditions.
22 This is demonstrated by the fact that Defendants solicited Plaintiff
23 at the age of twelve to leave her family in New Mexico and move to
24 California to live and work at Defendants’ facilities.
25 //
26 //
27 //
28 //
37

1 86. Plaintiff reasonably relied on Defendants’

2 representations and moved from New Mexico to California for the
3 purpose of working for Defendants. It is logical for a twelve year
4 old to believe that she will be permitted three weeks of vacation
5 time a year, that she will be allowed reasonable access to her
6 parents, and that she will work a average work week consistent with
7 being a minor, particularly when representations to that effect are
8 made. Moreover, it is logical for a twelve year old to believe that
9 she will continue to receive an education when moving to work and
10 live away from her family at a young age; a certain level of
11 education is mandated by law.
13 misrepresentations to Plaintiff in soliciting Plaintiff as an
14 employee, Plaintiff suffered lost income and education.
15 88. As a further direct and proximate result of
16 Defendants’ misrepresentations to Plaintiff in soliciting Plaintiff
17 as an employee, Plaintiff suffers from emotional distress, including
18 anxiety, embarrassment, humiliation, shame, depression, feelings of
19 powerlessness, and anguish.
20 89. Plaintiff’s reliance on Defendants’ aforementioned
21 representations was a substantial factor in causing Plaintiff harm
22 as Plaintiff would not have moved away from her home and family or
23 foregone her formal education in the absence of relying on
24 Defendants’ representations.
25 89. Plaintiff seeks to recover damages for her lost income
26 and education and for her emotional distress in a sum to be
27 established according to proof.
28 //
38

1 90. Plaintiff also was harmed during her work for

2 Defendants because she was paid less than the minimum wage and was
3 not paid overtime. Defendants paid Plaintiff less than the minimum
4 wage during Plaintiff’s entire employment with Defendants, from 1991
5 to 2004. Further, during Plaintiff’s employment with Defendants, from
6 1991 to 2004, Plaintiff routinely worked overtime and Defendants did
7 not pay Plaintiff for that overtime.
8 91. Plaintiff seeks to recover lost wages, with interest,
9 for all of the years that she worked for Defendants and was not paid
10 minimum wage.
11 92. Plaintiff also seeks to recover overtime compensation,
12 with interest, due her for all of her hours of unpaid overtime work
13 for Defendants.
14 93. Plaintiff also seeks to recover penalties pursuant to
15 Labor Code Section 203 in an amount equivalent to wages from the date
16 of the cessation of Plaintiff’s employment with Defendants to the
17 present date and to the date of judgment, because Defendants wilfully
18 failed to pay Plaintiff wages owed to Plaintiff on the date of the
19 cessation of her employment, have continued to fail to pay such wages
20 to the present date, and will continue to fail to pay such wages to
21 Plaintiff until judgment is rendered and paid in this action.
22 94. Plaintiff also seeks to recover reasonable attorney’s
23 fees according to proof pursuant to applicable provisions of the
24 Labor Code.
26 reasonably have discovered that she had a claim against Defendants
27 for Defendants’ false representations in soliciting Plaintiff’s
28 employment and Defendants’ failure to pay minimum wage and overtime
39

1 pay because Plaintiff was enmeshed in a confidential relationship

2 with Defendants and was brainwashed by Defendants such that she had
3 no comprehension of her legal rights. The confidential relationship
4 that existed between Plaintiff and Defendants, as well as the
5 brainwashing to which Plaintiff was subjected, are demonstrated by
6 the following:
40


41

14 96. Further, from approximately 1991 to 2004, Plaintiff
15 could not reasonably have discovered that she had a claim against
16 Defendants for Defendants’ failure to pay minimum wage and overtime
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
20 her rights to minimum wage and her rights to overtime compensation.
28 suicide.
42


27 //
28 //
43


44


16
17 SEVENTH CAUSE OF ACTION
18 FOR VIOLATION OF BUSINESS AND PROFESSIONS CODE
19 SECTION 17200, ET SEQ.
22
23 102. During Plaintiff’s employment with Defendants from
24 approximately 1991 to 2004, and upon Plaintiff’s termination of her
25 employment with Defendants, Defendants engaged in unlawful, unfair
26 and fraudulent business practices.
27 //
28 //
45

1 103. Defendants’ unlawful, unfair and fraudulent business

2 practices include:
3 (A) Defendants’ internal policy of coercing and
4 forcing their female employees, including Plaintiff, to have
5 abortions, so as to maximize the workload from female employees and
6 to avoid child care issues.
7 (B) Defendants’ repeated confinement of their
8 employees, including Plaintiff, to the RPF by means of threats,
9 intimidation, and coercion.
10 (C) Defendants’ practice of threatening to disclose
11 embarrassing and confidential information about their employees,
12 including Plaintiff, when Defendants detect their employees want to
13 leave their facilities or fail to comply with Defendants’ policies
14 or orders.
15 (D) Defendants’ practice of imposing substantial
16 “Freeloader Debts” on former employees, including Plaintiff, for
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 Plaintiff when she left Defendants’ facilities in 2004. Plaintiff
20 paid this debt long after leaving Defendants’ facilities.
21 (E) Defendants’ solicitation of employees, including
22 Plaintiff, through false representations regarding the workers’
23 access to their parents, schedule, and education that they will
24 receive as employees when working and living at Defendants’
25 facilities.
26 (F) Defendants’ policy of paying their employees,
27 including Plaintiff, less than the legal minimum wage.
28 //
46

1 (G) Defendants’ policy of requiring employees,

2 including Plaintiff, to work more than eight hours a day and more
3 than forty hours per week without paying these employees overtime
4 compensation.
5 (H) Defendants’ refusal to post Wage and Hour Notices
6 informing their employees of their rights as workers.
7 (I) Defendants’ practice of coercing employees,
8 including Plaintiff, into signing documents upon their termination
9 that purport to release all claims against Defendants, prevent
10 employees from saying anything negative about Defendants, and
11 purport to subject employees to significant penalties/fines if said
12 agreements are not adhered to in full.
14 unlawful, unfair and fraudulent business practices, Plaintiff
15 suffered lost employment income and monies which she paid to
16 Defendants on her “freeloader debt.”
17 105. Defendants’ unlawful, unfair and fraudulent business
18 practices were a substantial factor in causing Plaintiff to sustain
19 said economic losses.
20 106. Plaintiff seeks restitution for unpaid wages and the
21 monies which she paid to Defendants on her “freeloader debt,” in a
22 sum to be established according to proof, pursuant to Business and
23 Professions Code Sections 17200, et seq., especially Business and
24 Professions Code Section 17204.
25 107. Plaintiff also seeks an injunction against Defendants’
26 unlawful, unfair and fraudulent business practices pursuant to
27 Business and Professions Code Sections 17200, et seq., especially
28 Business and Professions Code Section 17203.
47

1 108. Plaintiff further seeks reasonable attorney's fees

2 according to proof pursuant to the Labor Code and pursuant to
3 California Code of Civil Procedure Section 1021.5 . This claim is
4 made for the public good and to discourage this outrageous conduct
5 from continuing in the future.
7 reasonably have discovered that she had a claim against Defendants
8 for Defendants’ unfair and fraudulent business practices because
9 Plaintiff was enmeshed in a confidential relationship with Defendants
10 and was brainwashed by Defendants such that she had no comprehension
11 of her legal rights. The confidential relationship that existed
12 between Plaintiff and Defendants, as well as the brainwashing to
13 which Plaintiff was subjected, are demonstrated by the following:
27 //
28 //
48


49


23 110. Further, from approximately 1991 to 2004, Plaintiff
24 could not reasonably have discovered that she had a claim against
25 Defendants for Defendants’ unfair and fraudulent business practices
26 of failing to pay minimum wage and overtime pay because Defendants
27 did not post the wage and hour notices that they legally were
28 required to post in Plaintiff’s workplace. Without these wage and
50

1 hour notices, Plaintiff did not have actual notice of her rights to
2 minimum wage and her rights to overtime compensation.
3 111. As alleged in earlier paragraphs, in 2004, Plaintiff
4 learned that after years of work in the RPF and after completing all
5 of the tasks required of her multiple times over, Plaintiff 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
10 suicide.
51


12 signed upon leaving Defendants’ facilities. During this time, 2004
13 to 2008, Plaintiff remained a loyal follower of the Church of
23 that she owed Defendant, Church of Scientology International,
24 approximately $120,000 for her on-the-job training since age twelve;
25 this is commonly referred to by the Church of Scientology as a
26 “Freedloader Debt.” Plaintiff continued paying this purported
27 “Freeloader Debt” well after leaving Defendants’ facilities in 2004
28 based upon her genuine belief in Defendants’ representations
52

1 regarding her legal rights and obligations. Moreover, Plaintiff

2 continued to purchase the Church of Scientology’s literature and
3 assisted local missions in collecting “donations” for the Church of
4 Scientology.
24 //
25 //
26 //
27 //
28 //
53

1 PRAYER FOR RELIEF

2
3 WHEREFORE, Plaintiff prays for judgment as follows:
4 1. For general damages in a sum in excess of the minimum
5 jurisdictional amount of the court;
6 2. For loss of earnings according to proof;
7 3. For loss of education damages according to proof;
8 4. For emotional distress damages according to proof;
9 5. For unpaid wages, including interest, according to
10 proof;
11 6. For injunctive relief preventing forced abortions,
12 deprivation of liberty, and unfair and fraudulent business practices;
13 7. For restitution of unpaid wages, unpaid overtime wages,
14 and monies that Plaintiff paid to Defendants pursuant to Labor Code
15 § 1194 et al., and pursuant to Bus. & Prof. Code § 17200, et al.
16 8. For civil penalties pursuant to Labor Code § 203 et al.
17 9. For reasonable attorney's fees pursuant to Labor Code
18 § 218.5 and C.C.P. § 1021.5.
19 10. For pre- and post-judgment interest allowed by law;
20 11. For Plaintiff's costs of suit incurred herein; and,
21 12. For such other and further relief as the Court deems
22 just and proper.
23
24 DATE: February 2, 2010 METZGER LAW GROUP
A Professional Law Corporation
25
26
____________________________________
27 RAPHAEL METZGER, ESQ.
Attorneys for Plaintiff,
28 Laura Ann DeCrescenzo
54

1 DEMAND FOR JURY TRIAL

2
3 Pursuant to Cal. Code of Civil Procedure § 600 et seq. (and
4 Rule 38 of the Federal Rules of Civil Procedure should this case ever
5 be removed to federal court), Plaintiff hereby demands trial by jury
6 of all issues which may be tried to a jury.
7
8 DATE: February 2, 2010 METZGER LAW GROUP
A Professional Law Corporation
9
10
11
____________________________________
12 RAPHAEL METZGER, ESQ.
Attorneys for Plaintiff,
13 Laura Ann DeCrescenzo
14
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28
55

1 PROOF OF SERVICE
2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES )
3 I am employed in the County of Los Angeles, State of California.

I am over the age of 18 years and am not a party to the within action. My
4 business address is 401 East Ocean Blvd., #800, Long Beach, CA 90802.
5 On February 2, 2010, I served the foregoing document, described

as: SUMMONS ON SECOND AMENDED COMPLAINT; SECOND AMENDED COMPLAINT on the
6 parties to this action as follows:
7 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
on 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 I am aware that on motion of any party served, service is presumed invalid
if the postal cancellation date or postage meter date is more than one day
11 after the date of deposit for mailing set forth in this affidavit.
12 (BY FACSIMILE) I served the foregoing document by faxing

true copies thereof from facsimile number (562) 436-1561, to the facsimile
13 numbers indicated on the attached list. Said document was transmitted by
facsimile transmission, which was reported complete and without error.
14
(BY PERSONAL SERVICE) I caused to be delivered such
15 document by hand to the firms listed on the attached list where personal
service is indicated.
16
(BY E-MAIL) I delivered such document by electronic mail
17 to the firms listed on the attached list.
18 (BY OVERNIGHT MAIL) I caused such document to be delivered

to the firms indicated on the attached list by Express Mail or by another
19 express service carrier, by placing the document in an envelope designated
by the carrier and addressed as indicated on the attached list, with the
20 delivery fees provided for, and depositing same in a box or facility
regularly maintained by that carrier or by delivering same to an authorized
21 courier or driver authorized by the carrier to receive documents.
22 X (STATE) I declare under penalty of perjury under the laws

of the State of California that the above is true and correct.
23
(FEDERAL) I declare that I am employed in the offices of
24 a member of this court, at whose direction service was made.
25 Executed on February 2, 2010, at Long Beach, California.
26
27 Nina S. Vidal, Declarant
28
56

1 SERVICE LIST
(DeCrescenzo v. Church of Scientology, Case No. BC411018)
2
-o0o-
3
Barry Van Sickle, Esq.
4 1079 Sunrise Avenue, Suite B-315
Roseville, ca 95661
5 (Plaintiff)
6 Anthony J. Oncidi, Esq.

Harold M. Brody, Esq.
7 Proskauer Rose
2049 Century Park East, Suite 3200
8 Los Angeles, CA 90067-3206
(Church of Scientology International)
9
Kendrick L. Moxon, Esq.
10 Moxon & Kobrin
3055 Wilshire Blvd., Suite 900
11 Los Angeles, CA 90010
(Church of Scientology International)
12
13
14 (Updated December 29, 2009 kk)
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57

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F:\WP\Cases\9527\PLEADDOC\COMPLAIN\SAC - Revised.

1 BARRY VAN SICKLE, ESQ., SBN 98645

SECOND AMENDED COMPLAINT

1 Plaintiff, Laura Ann DeCrescenzo, hereby alleges:

SECOND AMENDED COMPLAINT

SECOND AMENDED COMPLAINT

1 FIRST CAUSE OF ACTION

SECOND AMENDED COMPLAINT

1 children is one of the most intimate and fundamental of all

SECOND AMENDED COMPLAINT

1 15. Defendants’ conduct in forcing Plaintiff to have an

SECOND AMENDED COMPLAINT

1 Scientology and would be allowed to move “up the bridge” of

SECOND AMENDED COMPLAINT

1 (D) Plaintiff had little formal education or

SECOND AMENDED COMPLAINT

1 (I) Plaintiff spent the entirety of her formative

SECOND AMENDED COMPLAINT

SECOND AMENDED COMPLAINT

1 when Plaintiff left Defendants’ facilities in 2004, she was informed

SECOND AMENDED COMPLAINT

SECOND AMENDED COMPLAINT

1 26. As a direct and proximate result of Defendants’

SECOND AMENDED COMPLAINT

1 30. As a direct and proximate result of Defendants’

SECOND AMENDED COMPLAINT

SECOND AMENDED COMPLAINT

1 (D) Plaintiff had little formal education or

SECOND AMENDED COMPLAINT

1 (I) Plaintiff spent the entirety of her formative

SECOND AMENDED COMPLAINT

SECOND AMENDED COMPLAINT

1 when Plaintiff left Defendants’ facilities in 2004, she was informed

SECOND AMENDED COMPLAINT

1 reading the stories of her friends in July 2008 that Plaintiff

SECOND AMENDED COMPLAINT

1 that Defendants would disclose embarrassing information about

SECOND AMENDED COMPLAINT

1 44. Plaintiff reasonably believed that if she exercised

SECOND AMENDED COMPLAINT

1 by means of threats, coercion, and intimidation on the part of

SECOND AMENDED COMPLAINT

1 50. Plaintiff believed she would not be allowed to leave

SECOND AMENDED COMPLAINT

1 by the Church of Scientology as a “Freedloader Debt.” Plaintiff

SECOND AMENDED COMPLAINT

1 FOURTH CAUSE OF ACTION

SECOND AMENDED COMPLAINT

1 friends and co-workers at Defendants’ facilities, and that Defendants

SECOND AMENDED COMPLAINT

1 out of Defendants’ facilities and end her employment, Plaintiff faked

SECOND AMENDED COMPLAINT

1 63. From approximately 2004 to July 2008, Plaintiff, to

SECOND AMENDED COMPLAINT

1 and her family members were forbidden by the Church of Scientology

SECOND AMENDED COMPLAINT

1 66. Defendants’ conduct that was intended to cause

SECOND AMENDED COMPLAINT

1 69. As described in preceding paragraphs, Plaintiff also

SECOND AMENDED COMPLAINT

1 72. Defendants’ conduct in subjecting Plaintiff to years

SECOND AMENDED COMPLAINT

1 Defendants represented to Plaintiff that by signing these documents,

SECOND AMENDED COMPLAINT