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Scientology moves to dismiss the ‘Jane Doe’ lawsuit in Miami, and we have the docs

[Proof that David Miscavige has done business in Miami]

We’ve told you how Scientology has reacted to the first two of three big lawsuits filed against it this year, and now we have some new documents showing how they’re reacting to the third.

The first lawsuit, filed in Los Angeles by a powerful national legal team, was on behalf of Valerie Haney, Leah Remini’s assistant and the former personal steward to David Miscavige at Scientology’s secretive Gold Base. Miscavige and the other Scientology entities named as defendants are challenging the service of this lawsuit, calling it “fraudulent,” and all but Miscavige are asking not only to quash the service but also to award them sanctions.

That’s also the approach the church has taken in the second lawsuit, which was filed in Los Angeles on behalf of four women who allege they were violently raped by Scientologist actor Danny Masterson. They’re suing Miscavige and the church over allegations that they were harassed once they came forward to law enforcement in 2016, and they are joined in those allegations by plaintiff Chrissie Carnell Bixler’s husband, rocker Cedric Bixler-Zavala. Miscavige and the Scientology entities are trying to quash the service of the lawsuit, and have asked for sanctions.

The reaction to the third lawsuit is very different. It was filed in Miami on September 18 on behalf of a woman who is going by the name Jane Doe, and who alleges she was subjected to sick sexual abuse as a small child at the Scientology school Clearwater Academy, and then later, still as a child, when she was sent to work in Venezuela at a Scientology church and then again when she was brought back to Clearwater. She too is alleging that Scientology leader David Miscavige has orchestrated a harassment campaign of her once she began to come forward about her allegations.

This time, however, the defendants who have responded are not challenging the service of the lawsuit, but instead are focusing on where it was filed, in Miami.


According to Jane Doe’s lawsuit, she was molested in Clearwater (which is located in Pinellas County) and Venezuela, and she is suing Scientology entities like the Flag Service Organization, which is in Clearwater, and the Church of Scientology International and the Religious Technology Center, which are based in California. According to the lawsuit, it was being filed in Miami because those organizations “do business” and have “agents and representatives” there.

But Scientology argues that the lawsuit was simply filed in the wrong place.

No parties are located in Miami-Dade County (including Plaintiff), no evidence and likely no witnesses are located in Miami-Dade County, and none of the alleged torts occurred in Miami-Dade County. Rather, Plaintiff’s claims appear to have a nexus to Pinellas County, Florida. Accordingly, this action should be transferred to Pinellas County.

Also, the Scientology entities are arguing that even if the court finds that Miami is a proper venue, and even if it decides the California entities (CSI, RTC) can be sued there, the church says it will then move to have the case sent to its internal arbitration.

In other words, Scientology is hoping to shove this case into its own kangaroo court system, which it did successfully with another lawsuit filed in Florida, the fraud lawsuit filed by Luis and Rocio Garcia in 2013. Although the Garcias alleged that they had been criminally defrauded when they were lied to about the donations they were asked to give, the court bought Scientology’s argument that because the Garcias had signed draconian membership agreements that compelled arbitration, there was nothing the court could do about it. (That decision is still on appeal.)

But sure, why not. Scientology was already successful putting one lawsuit into limbo with that argument, and they’re prepared to do it again, even though the criminal aspect alleged in this lawsuit is so much worse than what was alleged in the Garcia case. Although Jane Doe claims she was subjected to three separate cases of being molested while under Scientology’s care, the church believes her “grievances” should be heard not in a court of law but in a sort of Scientology court martial overseen by three Scientologists in good standing.

The motions to dismiss from Scientology also argue that Jane Doe has waited too long to bring her case, saying that she can’t sue over things that happened 20 years ago, when she was in kindergarten. (She’s 25 now.)

The motions make additional arguments, and they fit with what we’ve seen from Scientology in the past. Plaintiffs tend to file lawsuits alleging that Scientology is a unified, worldwide body that operates under the micromanaging David Miscavige while it harms people and their families (and countless examples and previous litigation bears this out). But in court, Scientology is quick to make use of its early 1980s reorganization, and claim that its many entities have nothing to do with each other, and that Miscavige is simply an “ecclesiastical” pontiff-like figure. So even though Scientology might have an “Ideal Org” in Miami with staff that reports directly to headquarters, RTC argues that it has nothing to do with Miami or even with the Flag Land Base in Clearwater.

For an example of how far they take this transparent attempt at hiding the ball, there’s this quote from the motion submitted by the Church of Scientology International (CSI). As to the allegation by Jane Doe that when she was 14 years old a woman in the HCO office in Clearwater sexually abused her, CSI writes…

As for Ms. Richie supposedly being a “member” of CSI, CSI does not even know what that means. CSI is a corporation and does not have “members.” Furthermore, CSI does not have any property in Florida, so the allegation that an assault took place on CSI property is fabricated as well.

We note that in the lawsuit, Jane Doe doesn’t actually refer to the HCO woman as being a “member” of CSI, so we’re not even sure what CSI is complaining about, but you can see Scientology’s strategy is always the same. David Miscavige, at the annual events, does his best to give the impression that Scientology is everywhere, all over the planet, and is expanding like no other religion ever has. But when it is taken to court, Scientology says, “you can’t sue us, we have no members, no employees, we own no property, and we don’t even know what this ‘Florida’ thing is.”

Meanwhile, there is no response in yet from Miscavige himself. Will he be challenging service like in the other lawsuits, or file his own motion to dismiss based on the venue? We can hardly wait to find out.

And we’re also interested to see how Jane Doe’s legal team responds. It does strike us a little odd that if all of the parts of her story took place in Clearwater and Venezuela, Miami might be an odd choice of venue.

Here’s RTC’s motion to dismiss…


Jane Doe vs. Scientology: R… by Tony Ortega on Scribd


Bonus items from our tipsters

It’s another viewing party, this time at the Celebrity Centre…



Leaked document of the day

From the Mace-Kingsley Ranch documents release comes this item.

There was something about this handwritten note in the Mace Kingsley documents that made us pause. If you’ve heard about what the ranch was like from people like Nathan Rich and Tara Dawn, you know how children were terrorized at that misguided place. But to get out of there, they had to do mindless Scientology exercises and write up plausible “success stories” to prove that they were ready to move on to the next step.

Dinky words, indeed.



Jan 10, 90


Dinky Words II

I had alot of fun doing this course and I learend alot. I learned what little words ment.



Source Code

“Every thetan is, unless he’s knocked flat out — you know, unless he’s been eating some of the recent food preservatives — this fellow is operating to some degree, even if he’s just an effect. You see, he’s, he still can put out an impulse. See, he’s mostly effect, but he can put out a little bit of an impulse, see? Well, actually that would be an interiorized thetan who was very wog. And the word ‘wog,’ of course, is in essence a ‘worthy oriental gentleman’ as been defined by the Royal Air Force. There’s nothing derogatory in being called a wog. As a matter of fact, that was the source of a general order issued in Egypt on the complaint of the Egyptian government. The air force officers were calling Egyptians wogs. So the commanding officer defined it. And he said, well, wog, that means ‘worthy oriental gentleman,’ and insisted his officers use it. Those were in the days when the Empire wasn’t dead! Anyway, this means a common, ordinary, run-of-the-mill, garden-variety humanoid. And a garden-variety humanoid means a person who has human characteristics. By which we define not that he is human in his treatment of things, he isn’t. It’s simply that he is a body, he is a body.” — L. Ron Hubbard, November 29, 1966


Overheard in the FreeZone

“Understanding how theta works in a MEST universe on a continuous basis is reversing the downhill spiral. You can never learn it enough. If you don’t audit thetans you end up alone with unconscious beings. And no comm lines. Scientology is a breakdown of MEST universe into its most basic components. If you even clear a planet that would be like wow, utopia. That’s why I haven’t given up on Scientology like others, just in case it can change. It has the structure there, just needs to get rid of the paranoia. Or run grade 4 on Miscavige so he stops running his 3rd dynamic surfacs.”


Random Howdy

“Scientology is a racist philosophy. It’s anti homo sapiens.”


Scientology’s celebrities, ‘Ideal Orgs,’ and more!

[Kelly Preston, Jason Dohring, and Anne Archer]

We’ve been building landing pages about David Miscavige’s favorite playthings, including celebrities and ‘Ideal Orgs,’ and we’re hoping you’ll join in and help us gather as much information as we can about them. Head on over and help us with links and photos and comments.

Scientology’s celebrities, from A to Z! Find your favorite Hubbardite celeb at this index page — or suggest someone to add to the list!

Scientology’s ‘Ideal Orgs,’ from one end of the planet to the other! Help us build up pages about each these worldwide locations!

Scientology’s sneaky front groups, spreading the good news about L. Ron Hubbard while pretending to benefit society!

Scientology Lit: Books reviewed or excerpted in our weekly series. How many have you read?



[ONE year ago] While Leah Remini asks for government action, the government covers for Scientology overseas
[TWO years ago] DOX: Sworn testimony that a U.S. state was too afraid to take on the Church of Scientology
[THREE years ago] As you watch Leah Remini’s show tonight, keep these people disappeared by Scientology in mind
[FOUR years ago] Jonny Jacobsen: Why the Moscow ban on Scientology may be built on shaky foundations
[FIVE years ago] Jon Atack excavates the Scientology mind for L. Ron Hubbard’s most harmful implants
[SIX years ago] Tonight: Scientology Gets Its IAS Gala On — Let’s Get Dauntless, Defiant, and Resolute!
[SEVEN years ago] Scientology’s Master Spies
[EIGHT years ago] Scientology’s Cruise Ship as Prison: The Voice Interviews Valeska Paris


Scientology disconnection, a reminder

Bernie Headley has not seen his daughter Stephanie in 5,643 days.
Valerie Haney has not seen her mother Lynne in 1,772 days.
Katrina Reyes has not seen her mother Yelena in 2,276 days
Sylvia Wagner DeWall has not seen her brother Randy in 1,796 days.
Brian Sheen has not seen his grandson Leo in 816 days.
Geoff Levin has not seen his son Collin and daughter Savannah in 707 days.
Christie Collbran has not seen her mother Liz King in 4,014 days.
Clarissa Adams has not seen her parents Walter and Irmin Huber in 1,882 days.
Carol Nyburg has not seen her daughter Nancy in 2,656 days.
Jamie Sorrentini Lugli has not seen her father Irving in 3,430 days.
Quailynn McDaniel has not seen her brother Sean in 2,776 days.
Dylan Gill has not seen his father Russell in 11,342 days.
Melissa Paris has not seen her father Jean-Francois in 7,261 days.
Valeska Paris has not seen her brother Raphael in 3,429 days.
Mirriam Francis has not seen her brother Ben in 3,010 days.
Claudio and Renata Lugli have not seen their son Flavio in 3,271 days.
Sara Goldberg has not seen her daughter Ashley in 2,310 days.
Lori Hodgson has not seen her son Jeremy and daughter Jessica in 2,022 days.
Marie Bilheimer has not seen her mother June in 1,548 days.
Charley Updegrove has not seen his son Toby in 1,074 days.
Joe Reaiche has not seen his daughter Alanna Masterson in 5,637 days
Derek Bloch has not seen his father Darren in 2,777 days.
Cindy Plahuta has not seen her daughter Kara in 3,097 days.
Roger Weller has not seen his daughter Alyssa in 7,953 days.
Claire Headley has not seen her mother Gen in 3,072 days.
Ramana Dienes-Browning has not seen her mother Jancis in 1,427 days.
Mike Rinder has not seen his son Benjamin and daughter Taryn in 5,730 days.
Brian Sheen has not seen his daughter Spring in 1,836 days.
Skip Young has not seen his daughters Megan and Alexis in 2,238 days.
Mary Kahn has not seen her son Sammy in 2,110 days.
Lois Reisdorf has not seen her son Craig in 1,693 days.
Phil and Willie Jones have not seen their son Mike and daughter Emily in 2,188 days.
Mary Jane Barry has not seen her daughter Samantha in 2,442 days.
Kate Bornstein has not seen her daughter Jessica in 13,551 days.


Posted by Tony Ortega on November 29, 2019 at 07:00

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Our new book with Paulette Cooper, Battlefield Scientology: Exposing L. Ron Hubbard’s dangerous ‘religion’ is now on sale at Amazon in paperback and Kindle formats. Our book about Paulette, The Unbreakable Miss Lovely: How the Church of Scientology tried to destroy Paulette Cooper, is on sale at Amazon in paperback, Kindle, and audiobook versions. We’ve posted photographs of Paulette and scenes from her life at a separate location. Reader Sookie put together a complete index. More information can also be found at the book’s dedicated page.

The Best of the Underground Bunker, 1995-2018 Just starting out here? We’ve picked out the most important stories we’ve covered here at the Underground Bunker (2012-2018), The Village Voice (2008-2012), New Times Los Angeles (1999-2002) and the Phoenix New Times (1995-1999)

Other links: BLOGGING DIANETICS: Reading Scientology’s founding text cover to cover | UP THE BRIDGE: Claire Headley and Bruce Hines train us as Scientologists | GETTING OUR ETHICS IN: Jefferson Hawkins explains Scientology’s system of justice | SCIENTOLOGY MYTHBUSTING: Historian Jon Atack discusses key Scientology concepts | Shelly Miscavige, 14 years gone | The Lisa McPherson story told in real time | The Cathriona White stories | The Leah Remini ‘Knowledge Reports’ | Hear audio of a Scientology excommunication | Scientology’s little day care of horrors | Whatever happened to Steve Fishman? | Felony charges for Scientology’s drug rehab scam | Why Scientology digs bomb-proof vaults in the desert | PZ Myers reads L. Ron Hubbard’s “A History of Man” | Scientology’s Master Spies | The mystery of the richest Scientologist and his wayward sons | Scientology’s shocking mistreatment of the mentally ill | The Underground Bunker’s Official Theme Song | The Underground Bunker FAQ

Watch our short videos that explain Scientology’s controversies in three minutes or less…

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Our non-Scientology stories: Robert Burnham Jr., the man who inscribed the universe | Notorious alt-right inspiration Kevin MacDonald and his theories about Jewish DNA | The selling of the “Phoenix Lights” | Astronomer Harlow Shapley‘s FBI file | Sex, spies, and local TV news | Battling Babe-Hounds: Ross Jeffries v. R. Don Steele


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