Just days before a major showdown hearing was scheduled for April 20 (and was likely to be put back for the pandemic), “Jane Doe” has filed a new amended complaint in her lawsuit against the Church of Scientology and its leader David Miscavige that will upend scheduling in the case.
The new complaint admits that some seven months after the lawsuit was initially filed, Jane Doe’s attorneys have still not been able to locate Miscavige to serve him, saying that he has “concealed his whereabouts and evaded service.” But because Miscavige operates in Florida through his various Scientology enterprises, he can be sued there with the Florida secretary of state becoming his agent for service, they claim.
The new complaint then spends a lot more time than before compiling evidence that Miscavige operates Scientology in Florida in major ways, which is an answer to what has been Scientology’s biggest complaint about this lawsuit: That it was filed in the wrong place.
Jane Doe’s allegations are that she was sexually assaulted as a child while a student at Clearwater Academy, a Scientology school, and while working for Scientology in Venezuela and Clearwater, and not in Miami, where the lawsuit was filed. But the new complaint goes to great pains to establish that with major centers in Florida, it’s the proper place to sue the church, even in Miami:
Defendant Miscavige is the leader of “The Church of Scientology.” While Defendant Miscavige’s official title is the Chairman of the Board of RTC, Scientology’s website designates him as the “ecclesiastical leader of the Scientology religion.”
AdvertisementDefendant Miscavige directs, operates, supervises, and/or controls the Institutional Defendants, including their suborganizations or divisions, and Clearwater Academy and directs these entities’ activities.
Defendant Miscavige and RTC are tasked with ensuring that all Scientology organizations and members, including those in Florida, comply with Scientology policies.
Defendant Miscavige “bears the ultimate responsibility for ensuring” Scientology’s “standard and pure application,” “for [k]eeping Scientology [w]orking,” and for “guaranteeing the continued growth and expansion of Scientology internationally,” including in Florida….Under Defendant Miscavige’s direction, the church of Scientology established its “Flag Campus” in Florida to host Scientologists who make pilgrimages to the facility. The church of Scientology collects millions of dollars weekly from its activities in Florida, through fundraising and payments for religious counseling sessions offered exclusively at the Florida Flag Campus. Scientologists who make the pilgrimage to Florida are expected to stay in Scientology-owned hotels and eat at Scientology-owned restaurants during their stay.
The Flag Campus is the international headquarters for the Church of Scientology.
Defendant Miscavige maintains office space at three separate Scientology-owned buildings in Clearwater, Florida.
Each year, Defendant Miscavige officiates a celebration in Florida to honor Scientology founder L. Ron Hubbard’s birthday, hosting Scientologists from over seventy nations….According to the Scientology website’s “David Miscavige” page, “[n]owhere is the growth of Scientology religion more evident than at Flag, its spiritual headquarters in Clearwater, Florida”….RTC “grants [CSI], the mother church of the Scientology religion, the right to use the trademarks and to license their use to all other Scientology churches,” including those located in Clearwater, Orlando, Fort Lauderdale, Tampa, and Miami, Florida.
We’re pretty certain, however, that Scientology will continue to insist that Miami is not the proper venue for the lawsuit, and it may be some time before we can get a ruling from the court on that.
As for the sick allegations in this lawsuit about what happened to Jane Doe, we’ll just include them here in full.
Jane Doe was born into Scientology on September 19, 1994. Jane Doe attended Clearwater Academy. Clearwater Academy is a Scientologist school serving Pre-K to twelfth grade. During her years there in grades K1 and part of K2, Jane Doe was repeatedly sexually assaulted by an employee of Clearwater Academy. This abuse, which occurred on school property and during school hours while Clearwater Academy was acting in loco parentis of Jane Doe, included, but was not limited to:
a. Multiple instances when the employee forced Jane Doe and other young girls to perform sexual acts on each other;
b. Multiple instances when the employee masturbated in the presence of Jane Doe and ejaculated on Jane Doe; and
c. At least once instance when the employee forced his penis into Jane Doe’s mouth.Jane Doe reported this abuse to other employees of Clearwater Academy on multiple occasions, yet Clearwater Academy took no action to investigate, collect or preserve
evidence of the assault, and/or discipline or remove the employee from the school, thus promoting and encouraging further harm to Jane Doe and giving the abuser continued access to Jane Doe, thereby assisting the abuse. Even after Clearwater Academy was made aware of the abuse, the abuse continued.AdvertisementOther employees of Clearwater Academy would facilitate the abuse by calling Jane Doe from her classroom and sending her to be alone with her abuser. Clearwater Academy’s employees, agents, and/or representatives’ failure to report the abuse despite their knowledge of the abuse, and their actions and statements to Jane Doe regarding the abuse, caused Jane Doe to believe that she was to blame for the sexual abuse occurring to her and that the abuser had Clearwater Academy’s authority and consent to abuse her.
After this time, when Jane Doe was only eleven years old, the Institutional Defendants and Miscavige removed her from Florida without her consent and sent her to live in
Caracas, Venezuela, without her parents. During this time, when Jane Doe was twelve years old, Jane Doe was violently sexually assaulted on the premises of the Caracas Org by the adult son of wealthy, high-ranking Scientologists. Jane Doe immediately reported this incident to her auditor. Jane Doe’s auditor got extremely angry at Jane Doe, instead of at her attacker, and subjected her to punishment as a result of the report.Specifically, the Institutional Defendants and Miscavige “sentenced” Jane Doe to three months of hard, physical labor. Other members were ordered not to speak to Jane Doe during this time. The Institutional Defendants and Miscavige issued a “non-enturbulation” order against Jane Doe, which is a form of punishment warning Jane Doe that she was at risk of losing good standing with Scientology because of her actions of “bringing-in” (or causing through her own actions) the sexual assault.
After Jane Doe completed her “sentence,” she was sent back to Clearwater, Florida, where she then became a member of the Sea Org at the age of 14. During her time as a member of the Sea Org, the Institutional Defendants and Miscavige repeatedly forced her to perform long hours of difficult physical labor for little to no wages and a number of the other abuses…
While Jane Doe was in the Sea Org, when she was approximately 14 or 15 years of age, she became acquainted with the Institutional Defendants’ agent, representative, member, and/or employee, Senior Persof of the Hubbard Communications Office, Katherine Richie a/d/a Catrin Ritchie a/k/a Catrin Zanini in Florida. The Hubbard Communications Office is a division of CSI, RTC, and Flag Service, and it establishes what is needed to keep the Church operating, supports the spiritual purpose of the Church, and issues directives to Scientologists regarding how to operate and direct Scientology organizations. Katherine Richie arranged to become Jane Doe’s guardian with the approval of the Institutional Defendants and Miscavige. Once Jane Doe was under the control of Katherine Richie, Katherine Richie groomed Jane Doe to enter into a sexual relationship with her and Richie began sexually abusing Jane Doe, who was still a minor. This abuse occurred on property owned, controlled, managed, and/or operated by some number or all of the Institutional Defendants and Miscavige.
The Institutional Defendants and Miscavige’s agents and employees knew or should have known that Katherine Richie was abusing Jane Doe and should have prevented such abuses from occurring, but they did not, thus promoting and encouraging further harm to her. Upon information and belief, all Defendants were aware of all instances of abuse perpetrated upon Jane Doe yet all Defendants actively concealed the abuse and facts related thereto and obstructed any official investigation into the abuse by not reporting it to the appropriate authorities.
The Institutional Defendants and Miscavige continued to exploit Jane Doe in Florida, coercing her into forced labor for little or no pay until she eventually escaped from
Scientology in 2018. Since escaping Scientology, the Institutional Defendants and Miscavige have declared Jane Doe a suppressive person and launched a fair-gaming campaign in Florida against Jane Doe. The Institutional Defendants and Miscavige’s fair game attacks include, but are not limited to, tampering with Jane Doe’s vehicle, including cutting her brake lines; vandalizing her property; following her; surveilling her; and conducting hundreds of spam/crank phone calls to Jane Doe’s phone.
In all, Jane Doe is alleging 30 counts against the various defendants, which break down like this…
Counts 1-3: Sexual battery (Clearwater Academy, Flag Service Organization, Church of Scientology International)
Count 4: Battery (Clearwater Academy)
Count 5: Strict liability (Clearwater Academy)
Count 6: Duty to protect students (Clearwater Academy)
Count 8: Breach of fiduciary duty (Clearwater Academy)
Counts 9-12: Florida civil RICO (FSO, CSI, Religious Technology Center, David Miscavige)
Counts 13-16: False imprisonment (FSO, CSI, RTC, Miscavige)
Counts 17-21 Intentional infliction of emotional distress (Clearwater Academy, FSO, CSI, RTC, Miscavige)
Counts 22-25: Invasion of privacy (FSO, CSI, RTC, Miscavige)
Counts 26-30: Civil conspiracy (Clearwater Academy, FSO, CSI, RTC, Miscavige)
Although this amended complaint has beefed up the jurisdictional material, we expect that Scientology will continue to fight back in three ways: By keeping David Miscavige unavailable for service, by arguing that the lawsuit was filed in the wrong place, and by bringing a motion to compel arbitration in an attempt to stay the suit and force Jane Doe into Scientology’s internal “committee of evidence” procedure.
But at least we’re seeing some evidence that Jane Doe’s attorneys are fighting back, and with a narrative that paints Miscavige at the head of a conspiracy he controls through various subordinate entities.
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Mark Bunker gets on Downtown Development Board
We’re hoping that video of this becomes available…
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Bonus items from our tipsters
The Kaohsiung Ideal Org in Taiwan is still open for business! Come on in and get your temperature taken!
It’s never not a good time for a success story!
Give, give, give!
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“I only talk about animal psychologists because I want the beast to be known by his right name. That’s all he is and all he ever pretended to be. Any psychologist is an animal psychologist because the basic theory on which he operates is ‘man is an animal.’ So we call him animal psychologist. And I think that will effectively take care of that as the years roll along. Now, don’t ever use that word psychologist after this. See, just use animal psychologist, always. And you’ll get it around. You’ll find the Times, sooner or later, will be talking about the animal psychologist. And people will be phoning them up to take care of their horses. I wouldn’t let them though. And I don’t even like horses. I wouldn’t let them take care of my horse.” — L. Ron Hubbard, April 17, 1962
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“The core of this procedure is in the conversion of enmest and entheta back into mest and theta (aligned and balanced); one creates an equilibrium of forces which was in an imbalance, enturbulated; it converts enmest and entheta back into its rightful condition, which leads to more power, knowledge and beingness for the one causing it. Theta applies the laws of mest for the purposes of conquering it.”
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“It all depends on what the definition of a ‘win’ is. Somebody claiming they were cured of their asthma or allergies is ridiculous. Somebody saying that auditing made them happier is vague BS also. The only thing you ‘win’ in Scientology is the Booby Prize.”
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Full Court Press: What we’re watching at the Underground Bunker
Criminal prosecutions:
— Jay Spina: Sentencing was set for April 3 in White Plains
— Hanan and Rizza Islam and other family members: Trial set for October 7 in Los Angeles
Civil litigation:
— Luis and Rocio Garcia v. Scientology: Waiting for an appellate decision from the Eleventh Circuit
— Valerie Haney v. Scientology: Forced to ‘religious arbitration.’ Hearing on motion for reconsideration set for June 17
— Chrissie Bixler et al. v. Scientology and Danny Masterson: May 1 (Masterson new demurrer due), July 8 (plaintiff attorneys pro hac vice), August 31-Sept 1 (CSI/RTC demurrer against Riales, Masterson demurrer), Oct 7-19 (motions to compel arbitration)
— Jane Doe v. Scientology (in Miami): Jane Doe’s attorneys have asked for discovery, depositions (Warren McShane, Lynn Farny), amended complaint filed.
— Matt and Kathy Feschbach bankruptcy appeal: Oral arguments were heard on March 11 in Jacksonville
— Brian Statler Sr v. City of Inglewood: Amended complaint filed.
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Scientology’s celebrities, ‘Ideal Orgs,’ and more!
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?
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THE WHOLE TRACK
[ONE year ago] Spyentology: For Scientology, operating as an intelligence agency is a religious mandate
[TWO years ago] More proof that L. Ron Hubbard really did want Scientologists to consider him the Antichrist
[THREE years ago] Before Scientology’s Xenu was a genocidal galactic overlord, he was a … mountain?
[FOUR years ago] Louis Theroux’s ‘My Scientology Movie’ at Tribeca today, & more in our social media review
[FIVE years ago] Is France dropping its anti-Scientology fervor because Tom Cruise is just too délicieux?
[SIX years ago] Leah Remini ‘Fair Gamed’ by Scientology? Her sister gets a visit, and Tony Dovolani is tailed
[SEVEN years ago] Love in the Time of Miscavige
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Bernie Headley (1952-2019) did not see his daughter Stephanie in his final 5,667 days.
Valerie Haney has not seen her mother Lynne in 1,910 days.
Katrina Reyes has not seen her mother Yelena in 2,414 days
Sylvia Wagner DeWall has not seen her brother Randy in 1,934 days.
Brian Sheen has not seen his grandson Leo in 954 days.
Geoff Levin has not seen his son Collin and daughter Savannah in 845 days.
Christie Collbran has not seen her mother Liz King in 4,152 days.
Clarissa Adams has not seen her parents Walter and Irmin Huber in 2,020 days.
Carol Nyburg has not seen her daughter Nancy in 2,794 days.
Jamie Sorrentini Lugli has not seen her father Irving in 3,568 days.
Quailynn McDaniel has not seen her brother Sean in 2,914 days.
Dylan Gill has not seen his father Russell in 11,480 days.
Melissa Paris has not seen her father Jean-Francois in 7,399 days.
Valeska Paris has not seen her brother Raphael in 3,567 days.
Mirriam Francis has not seen her brother Ben in 3,148 days.
Claudio and Renata Lugli have not seen their son Flavio in 3,409 days.
Sara Goldberg has not seen her daughter Ashley in 2,447 days.
Lori Hodgson has not seen her son Jeremy and daughter Jessica in 2,160 days.
Marie Bilheimer has not seen her mother June in 1,685 days.
Charley Updegrove has not seen his son Toby in 1,215 days.
Joe Reaiche has not seen his daughter Alanna Masterson in 5,775 days
Derek Bloch has not seen his father Darren in 2,915 days.
Cindy Plahuta has not seen her daughter Kara in 3,235 days.
Roger Weller has not seen his daughter Alyssa in 8,090 days.
Claire Headley has not seen her mother Gen in 3,210 days.
Ramana Dienes-Browning has not seen her mother Jancis in 1,565 days.
Mike Rinder has not seen his son Benjamin and daughter Taryn in 5,868 days.
Brian Sheen has not seen his daughter Spring in 1,974 days.
Skip Young has not seen his daughters Megan and Alexis in 2,376 days.
Mary Kahn has not seen her son Sammy in 2,248 days.
Lois Reisdorf has not seen her son Craig in 1,831 days.
Phil and Willie Jones have not seen their son Mike and daughter Emily in 2,326 days.
Mary Jane Barry has not seen her daughter Samantha in 2,580 days.
Kate Bornstein has not seen her daughter Jessica in 13,689 days.
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Posted by Tony Ortega on April 17, 2020 at 07:00
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