COMES NOW Plaintiff Michael Pattinson, for his First Amended Complaint against these Defendants, and the Relief Defendants, and alleges as follows:

1. This First Amended Complaint is not directed at any of the Defendants' religious beliefs it is only directed at Defendants' secular policies, processes, policies, practices and conduct in connection with, at the very most, religiously motivated conduct which is subject to regulation for the protection of society. In addition, Plaintiff has standing to challenge the conduct of the Defendants' and the Relief Defendants, as alleged herein, because Plaintiff claims the Defendants and the Relief Defendants have, inter alia, violated the Establishment Clause of the First Amendment to the United States Constitution. Furthermore, the Scientology entities have been appointed compliance monitors with tax collection responsibilities in connection with their own tax compliance, and that of all Scientologists. Thus they are now 'state actors' for civil rights enforcement purposes.

2. A particularly large punitive damages award is requested because of Defendants' past activities and conspiracies to avoid paying previous civil judgments and punitive damage awards in cases such as: Christofferson, Armstrong, and Wollersheim, and the implementation of Defendants' "Mission Corporate Category Sort Out" in furtherance of their schemes to avoid having to satisfy civil judgments and punitive damages awards. Defendants have engaged in these fraudulent activities to avoid paying court ordered judgments despite the Scientology enterprise being a wealthy, international, deep-pocket enterprise with substantial assets both here in the United States as well as in secret foreign bank accounts, and gold and silver bars stored at Defendants' para-military base and "gulag" facility at Gilman Hot Springs, near Hemet, California. Defendants' assets are estimated to be many billions of dollars and are derived primarily from commercial, fraudulent and criminal activities.

3. Plaintiff Michael Pattinson was a member of various of the churches and corporations of Scientology for 25 years. During that time Defendants defrauded him of over $500,000 in money and engaged in activities intended to exploit him, and to later destroy him, which caused him financial ruin and the loss of considerable clientele and earning potential. In addition, Defendants' activities included the deprivation of his human rights and civil rights, kidnapping, false imprisonment and virtual slave labor. Defendants recruited Plaintiff into Scientology with fraudulent claims that they would cure his homosexuality without telling him that Scientology financially exploited the gay community, and gay Scientology celebrities, without disclosing that persons such as homosexuals, who are labeled 1. 1 ("covertly hostile") on Scientology's Tone Scale, are among the 2-1/2% of the world's population viewed as "antisocial" and who Scientology intends to exterminate when it takes over all political, economic, civil and religious institutions in the world, and rules the world according to Scientology's totalitarian policies and practices. Similarly, the fraud that Defendants perpetrated upon Plaintiff included misrepresentations and material nondisclosures regarding the life of L. Ron Hubbard, Scientology's Fair Game policy and practice of harassing critics, intimidating judges and lawyers, and engaging in litigation blitzkriegs with juggernauts of lawyers engaged in wars of attrition against opposing counsel and parties.

4. Defendants also misrepresented and failed to make material disclosures to Plaintiff regarding their extensive criminal history and numerous criminal convictions in the United States and various other nations, the numerous damning government investigations into Scientology around the world and the adverse opinions and judgments of courts in both the United States and other countries. Defendants also failed to disclose to Plaintiff that they are a para-military, totalitarian, political organization engaged in the blackmail and intimidation of Federal and State judges, and that they had intimidated and blackmailed the United States Internal Revenue Service into ignoring the adverse decisions of the highest courts of the land, and ignoring many years of prior Department of Justice and IRS policies, to obtain tax-free status in 1993 in circumstances where, upon their own admission, they would have been responsible for over $1 billion in past due and owing taxes to the Federal government alone. Similarly, Defendants also failed to disclose to Plaintiff that their "Bridge To Total Freedom" was in reality a 'Bridge To Total Servitude'. Moreover, Plaintiff was not told that the Defendants' auditing and other processes were often dangerous and, in a number of instances, constitute the illegal practice of medicine. Plaintiff was not told that the Church of Scientology was engaged in extensive, and unlawful lobbying of Federal government officials and legislatures for the purpose of having the United States Federal Government unconstitutionally intervene (in violation of the Establishment Clause) in the internal affairs of foreign nations, using United States foreign policy and the threat of trade sanctions, to further the Church of Scientology's so-called religious agenda in those countries such as Germany and Sweden. Defendants also failed to disclose to Plaintiff that they engaged in the systematic denial of the human rights and civil rights of both adherents and critics and that they operated heavily armed facilities where Scientology dissidents were subjected to concentration camp or gulag types of environments and treatment. Contrary to Defendants' representations that Scientology was compatible with, and could co-exist with, other religions, Defendants actually forcibly attempted to strip Plaintiff of his Christian beliefs as part of a secret Scientology policy to eradicate all of the world's religions individual by individual.

5. Plaintiff seeks compensatory damages of at least $500,000, special damages, punitive damages, attorneys' fees, declaratory relief and injunctive relief. Plaintiff also seeks declarations, among other things, that Defendants' disgorge the over $1 billion that they have admitted was otherwise due and owing to the United States Federal Government in 1993 and that Plaintiff's contract with Defendants, to serve Scientology for one billion years at $50. 00 per week, is voidable as being contrary to public policy.

6. This case arises, inter alia, under and is brought pursuant to the Racketeer Influenced and Corrupt Organizations laws (RICO), 18 U.S.C. Section 1961, et seq. Federal jurisdiction is expressly conferred by ? 18 U.S.C. 1964, 28 U.S.C. ? 1338(a), 28 U.S.C. ? 1330, U.S.C. ? 1983, U.S.C. ? 1985, et. seq., the matter in controversy exceeding $75,000 exclusive of costs and interest, the United States Government being a relief defendant by and through the individual relief defendants herein. Venue in this district is authorized under 18 U.S.C ? 1965 in that the Defendants herein reside, are found, have agents, have transacted or transact affairs within this district and that 'minimum contacts' and 'national contacts' exist. This Court has ancillary or pendant jurisdiction over the state law claims stated herein that they arise from a common nucleus of operative facts. The torts herein alleged involve a substantial identity of persons, wrongful conduct on the part of Defendants, and resulting damage to Plaintiff herein.

7. Plaintiff MICHAEL PHILIP PATTINSON ("Plaintiff") is an individual currently residing in the State of California, County of Los Angeles. Plaintiff is a citizen of the United Kingdom of England, Scotland, Wales and Northern Ireland. Plaintiff is a professional artist and the holder of a Master of Arts Degree from Dundee University in Scotland. Plaintiff has had a 25-year career internationally selling graphic art with over 99% of the sale of his art work being to private and corporate collectors. Plaintiff is the pioneer of the "musicalist" art style in that he paints visual renditions of pieces of music. This style has met with good success whenever properly marketed and not subjected to exploitation and destruction by the Defendants herein. Plaintiff has appeared on U.S. television with his art and has had exhibitions in over twelve different countries during his career as an artist. During almost the entirety of Plaintiff's artistic career, he has been a member of the various churches and corporations of Scientology which have, at various times, both exploited and destroyed his business of selling works of art and his life generally. Prior to, and during, his association with Defendants Plaintiff was and is a Christian.

8. The so-called religion of SCIENTOLOGY was founded by L. Ron Hubbard (hereinafter "Commodore Hubbard" or "Hubbard"), who set forth certain purported "scientific" theories in a number of writings published in the early-1950s, including: Dianetics: The Modern Science of Mental Health and Science of Survival: Prediction of Human Behavior. Subsequently, in or about the mid-1950s, and publications such as "Professional Auditor's Bulletin No. 32 (7 Aug., 1954)" Hubbard began representing that his published, and unpublished, theories were both alternatively "scientific" and "religious." Such representations were and are false and fraudulent and comprise some of the facts giving rise to Plaintiff's various claims for relief set forth herein. "Scientology [claims to be] the science of knowing how to know answers. It is an organized system of Axioms and Processes which resolve the problems of existence." (A Manual of the Dissemination of Material, 1955). However, the processes are fraudulent and dangerous and the axioms, like other writings of Commodore Hubbard, are plagiarized.

9. The Scientology entities named as Defendants herein are part of the single entity or juggernaut of Scientology. The corporate Defendants herein are components of the larger conglomeration of approximately 150 shell corporations, "fronts" and other organizations which, in the aggregate, are also referred to as Scientology and/or the Scientology Enterprise.

10. Defendant Church of Scientology International ("CSI") is, and at all relevant times was, a California corporation with its principal office in the City of Los Angeles, County of Los Angeles, State of California. As recently as October 29, 1997, CSI was found by the California Superior Court of Los Angeles County to be one of the alter ego-control entities of Scientology. CSI is currently the official Mother Church of Scientology. However, CSI is not a church within the traditional meaning of the word. It is a mere corporate middle management entity masquerading as a Church for tax exempt purposes. CSI houses the Scientology unit called the Office of Special Affairs ("OSA"). OSA is Department 20 on the Scientology Organization Board, or Org Board, and was formerly known as the Guardian's Office ("GO"). It is responsible for handling all external threats to the Scientology enterprise. OSA is the Scientology Enterprise's CIA-style intelligence and dirty tricks bureau. Its staff and spies practice "TR-L", a secret training routine, a claimed trade secret and copyrighted practice, inter alia, that teaches Scientologists how to effectively LIE. They also tell "acceptable truths." The overwhelming majority of the revenues of CSI (in excess of $40 Million a year) are used to fund a litigation juggernaut of lawyers, paralegals and private investigators conducting intelligence, intimidation, covert operations (both legal and illegal) litigation blitzkriegs and wars of attrition that, among other things, are intended to silence and punish critics of Defendants and to conceal the criminal, fraudulent and other activities perpetrated upon the Plaintiff and others, and to further the expansion of Scientology, and its worldwide totalitarian political domination, by any means whether legal or illegal. In addition, CSI operates an 800 plus acre facility at Gilman Hot Springs near Hemet, California, located in the California high desert. This facility masquerades as CSI's Golden Era Film Production studio but in reality is also known to senior Scientology executives as "the Base," or "Gold," and is the location of one of Scientology's Rehabilitation Project Force "re-education" facilities which are described by various former Scientology victims as a "gulag" or "concentration camp" styled punishment camp where people have been held under armed guard for years and at which others have simply disappeared. Although most Scientologists do not know where Captain Miscavige lives, his primary office and residence are also located at "the Base." The Base has been described in sealed testimony as a heavily fortified and dangerous facility which houses large stocks of munitions, bombs, assault weapons, a high mountain lookout and bunkers intended to repel a Waco-styled ATF or FBI assault. The Scientology organization takes unusual measures to prevent or punish those who would fly over the Base and take aerial photographs. The Base is also the location of facilities and amenities that unlawfully inure to the benefit of certain Scientology celebrities (Exhibit "A" hereto).

11. Defendant Church of Spiritual Technology ("CST") is, and at all relevant times was, a California non-profit corporation with its principal place of business in the City of Los Angeles, County of Los Angeles, State of California. "CST has the power . . . to [take] over the religious trademarks and use of the Advanced Technology, thereby gaining direct control over all Scientology Organizations . . ." Church of Spiritual Technology v. United States, 26b CL Ct. 713 aff.991 F.2d (sic) (1992) Accordingly CST, has ultimate power over the entire vast domain of all Scientology-related entities and individuals and businesses owned by Scientologists. CST does business as the L. Ron Hubbard library with its primary business address at a rental mailbox located at Village Mail Corp., 419 Larchmont, Box 162, Los Angeles, California. CST's founders and special directors are Lymon Spurlock, Sherman Lenske, Meade Emory and Leon Misterek. Lyman Spurlock is the only Scientologist and is a CPA. The other co-founders are non-Scientologist tax attorneys. Indeed, Meade Emory is a former assistant to the Commissioner of the Internal Revenue Service. Through a complex series of assignments and agreements, commencing in 1982, CST, doing business as the L. Ron Hubbard library, now owns all copyrights to all works created by L. Ron Hubbard, plus all copyrights to "look-alike" works that are "based on or derived from" the works of L. Ron Hubbard, but are "by" the Church of Scientology and others. In addition to owning and licensing all such copyrights, it possesses the right to seize all Scientology trademarks and to seize all of Scientology's so-called advanced technology. CST is a "low profile" Scientology entity the incorporation and activities of which were not disclosed to Plaintiff.

12. Defendant Religious Technology Center ("RTC") is, and at all relevant times was, a California corporation with its principal office in the City of Los Angeles, County of Los Angeles, State of California. As recently as October 29, 1997, RTC was found by the California Superior Court of Los Angeles County to be one of the alter-ego control entities of Scientology. RTC is one of the corporations that controls the copyrights and trademarks pertaining to the works of L. Ron Hubbard and various others. Its function is to preserve the "purity" of Scientology by constantly examining and critiquing all other Scientology entities, and businesses owned by Scientologists, regarding their operations, including the delivery of supposedly religious service "technology" as well as management operations. This gives it de facto command control over every aspect of every Scientology corporation, entity, business owned by a Scientologist, and individual Scientologist without regard to the alleged separate management and structure of such entities.

13. Relief Defendants William J. Clinton, Samuel R. Berger, Madeleine K. Albright, Robert E. Rubin, William K. Daley, Charlene Barshefsky and Michael P. Dolan, elected or appointed members of the Executive Branch of the United States Federal Government, are sued herein as Relief Defendants, and are solely sued for the purpose of making them "Relief Defendants" in connection with certain of the unlawful and unconstitutional activities alleged, including but not limited to multiple violations of the Establishment Clause of the First Amendment to the United States Constitution alleged of the Scientology and Scientology affiliated Defendants and for the sole purposes of the Declaratory and Injunctive Relief requested herein in the Twenty-Ninth Cause of Action. Plaintiff seeks no damages or other compensation from any of the Relief Defendants or from the U.S. Federal Government. Plaintiff does not allege that the Relief Defendants necessarily know of the various reprehensible and unconstitutional conduct set forth herein at the time they engaged in the excessive entanglement of Church and State. However, now that the Relief Defendants are on notice of these matters they should do no less than to convene Department of Justice, IRS, Senate, and Congressional inquiries into the actions of Defendants who are now "state actors' by virtue of express compliance and collection provisions of the IRS Secret Closing Agreement.

14. Defendant Church of Scientology of California ("CSC") is, and at all relevant times was, a California corporation with its principal office in the City of Los Angeles, County of Los Angeles, State of California. Until 1982, CSC was the Mother Church of the Church of Scientology. Plaintiff is informed and believes and based thereon alleges that in 1982, as part of a fraudulent and criminal conspiracy led by Defendant Captain Miscavige, and known as Mission Corporate Category Sort-Out ("MCCS"), and in order to avoid the claims of creditors, such as judgment creditor Lawrence D. Wollersheim, and other litigants, and the payment of properly due taxes and government supervision, CSC transferred its assets to other Scientology corporations and entities for no consideration.

15. Defendant Sea Organization ("Sea Org"), is, and its alter-ego Sea Org Reserves, Ltd., and at all relevant times was, an unincorporated California-based entity or association housed in the various business offices of that state's corporate party Defendants herein, and is one of the alter-ego entities which control the Scientology enterprise throughout the world. The Sea Org is an elite fraternal para-military and totalitarian organization comprised of various Sea Org units existing within the formalized structures of Scientology. The Sea Org is, in reality, the heart of R.I.C.O. enterprise alleged herein. Upon information and belief, Plaintiff alleges that the formalized structures of Scientology are mere corporate shells and shams operating in concert and under the directions of the Sea Org The various Sea Org units are the actual Scientology organization. The Sea Org is governed by the Sea Org Board, maintains its own bank accounts, and maintains the Sea Org reserves. The Sea Org is "the absolute power center" of the whole "Scientology" enterprise said to be located worldwide, including 150 satellite or affiliated entities claimed to exist in the United States and listed in the Clinton Administration's 1993 IRS letter "conditionally approving Defendants' tax exempt status." Defendant Sea Org Captain Miscavige sits alone as "the absolute power center," controlling absolutely by whatever traditional/Hubbard/ Miscavige means are required to further Scientology's worldwide political and economic takeover, whether lawful or unlawful. The Sea Org Reserves were not reported to the IRS, as part of the 1993 Scientology-IRS Settlement Agreement, notwithstanding their source being the various Scientology Section 501(c)(3) tax-exempt entities and the Plaintiff's monies, time and trust as set forth herein. The Sea Org reserves or bank accounts are used to hold, hide, transfer and manipulate funds properly belonging to the Scientology enterprise and beneficially owned by its members and, in part, contributed to by the Plaintiff.

16. At all times mentioned herein, Defendant Captain David Miscavige ("Captain Miscavige") was domiciled in the State of California and at various times, held numerous `posts', and wore numerous `hats', within Scientology, including being a Commodore's Messenger, Mission Ops/Mission Corporate Category Sort-out ("MCCS"), an Executive of ASI, the Chairman of the Board of Directors of RTC, the Managing Agent of CST, the Managing Agent of RTC, the Managing Agent of CSI, the head of the Sea Org, the worldwide ecclesiastical head of Scientology, and the Supreme Commander of Scientology, including the Pacific Area Command ("PAC") and holds the pseudo naval rank of Captain within the Sea Org, into which is paid a large portion of Scientology's vast tax free net income and profits contributed to partially by Plaintiff. In actuality, Captain Miscavige, is the Church of Scientology's Captain Bligh. At various relevant times herein, Captain Miscavige had direct oral and written communications with Plaintiff, including communications relating to his completion of the New OT-VII and New OT-VIII course levels, and thus, Captain Miscavige has unique and percipient knowledge as to certain of the relevant matters herein. In 1993, in a 1933 Nuremberg-Nazi like rally, Captain Miscavige proclaimed Scientology's "War against the IRS" (the United States Internal Revenue Service) to be over, with a saving of taxes and penalties otherwise due the United States Government, State Governments and local taxing authorities in the approximate amount of one billion dollars minus the twelve million dollars paid to I.R.S. in the secret settlement (Exhibits "B", "C", and "D" hereto). As part of said conditional settlement and secret closing agreement, the Clinton Administration agreed to permit Captain Miscavige and certain of the other Scientology Defendants to monitor, supervise and compel their own "compliance", and that of all Scientologists, with the tax laws of these United States thereby constituting the Defendants "state actors" and agents of the I.R.S. At all material times Captain Miscavige has used the Scientology Enterprise to implement and enforce both Commodore Hubbard's irrevocable policies and his own daily orders.

17. Defendant Author Services, Inc. ("ASI") is, and at all relevant times was, a California corporation with its principal office in the City of Los Angeles, County of Los Angeles, State of California. ASI was the alter-ego of L. Ron Hubbard and subsequently ASI was the alter-ego of Defendants Pat Broeker and Captain Miscavige. ASI is the corporate successor to the Scientology division which, prior to Commodore Hubbard's death, allegedly in 1996, handled all of Hubbard's personal accounts including his Scientology income of $1 million per week in 1980 (a period of time in which he claimed to be virtually uncompensated for his "contributions" to Scientology) and which virtually controlled the financial policies of all Scientology organizations. As such, ASI had control of the finances of non-profit corporations within Scientology and continues to do so. ASI is an integral, if not key part of Scientology and, at all pertinent times, was, and continues to be, an active participant in the conspiracy herein alleged.

18. At all times mentioned herein, Plaintiff is informed and believes and thereon alleges that Defendants Author Family Trust, and the Estate of L. Ron Hubbard, are entities that are residents of the State of California and subject to the control of Defendant Norman Starkey.

19. At all times herein, Defendant Norman Starkey was and is a "junior" or subordinate of Miscavige and/or L. Ron Hubbard, and since January 24, 1986 has functioned under a various array of titles, including: Executor of the Estate of L. Ron Hubbard and Trustee of Authors Family Trust; Executor of the Estate of L. Ron Hubbard; Executor of the Will of L. Ron Hubbard, d.b.a. L. Ron Hubbard Library; Executor of the Will of L. Ron Hubbard; Trustee of Authors Family Trust - B; Trustee of the Estate of L. Ron Hubbard and Trustee of Authors Family Trust; Trustee of Authors Family Trust - B d.b.a. L. Ron Hubbard Library and Trustee of Authors Family Trust. Among other things, Norman F. Starkey has been a principal participant in the fraudulent and unlawful transfer of approximately 8,000 copyrighted titles, between the years 1982 through to the present, in violation of applicable law and the rights of third parties including Commodore Hubbard's wife and heirs.

20. Defendant Religious Research Foundation is incorporated in Liberia and has been utilized by Defendants to channel monies contributed by Plaintiff into non-church accounts controlled by Commodore Hubbard and his successors for their personal and unlawful inurement.

21. Defendant the Commodore's Messengers Org ("CMO") is comprised of a group of Sea Org members who operate, using monies partially provided by Plaintiff, to ensure that the orders and whims of Commodore Hubbard and his successor Captain Miscavige are complied with instantly.

22. Defendant World Institute of Scientology Enterprises ("WISE") is, and at all relevant times was, a California corporation with its principal office in the City of Los Angeles, County of Los Angeles, State of California.

23. Defendant World Institute of Scientology Enterprises International ("WISE Int.") is, and at all relevant times was, a California corporation with its principal office in the City of Los Angeles, County of Los Angeles, State of California. WISE is represented as being a secular association for Scientology members who wish to be licensed to use Scientology's technology in their businesses and to pay licensing fees of ten percent (10%) of their gross income to the Church of Scientology for so doing. In reality, through these licensing arrangements, and coerced membership of Scientologists, and the employment of other Scientologists as employees who also must pay fixed donations to the Church, WISE is a massive money making commercial enterprise that funnels large revenues "up lines" to the now tax exempt Church in the form of the 10% licensing fees from the businesses' profits and fixed donations from the businesses' owners and employees. At any time, an RTC Mission can enter, search and make seizures at WISE businesses. WISE has been engaged in major commercial frauds perpetrated, among other places, in Germany and is currently, along with Applied Scholastics, the principal vehicle for the expansion of Scientology through Eastern Europe. Through this vehicle, and its recruiting fronts such as Sterling Management Services and Hollander, WISE recruits Eastern European businessmen to become members of WISE and then Scientologists who, through auditing, reveal sensitive commercial and governmental confidential information that is then utilized by the Scientology enterprise to advance its anti-social, undemocratic and unlawful goals. The 1993 secret IRS closing agreement between the Clinton administration and Scientology required Scientology to dissolve WISE. However, the same Clinton administration and Scientology agreement permits Scientology to be the actual monitor of its own compliance with United States tax laws and thus WISE continues to conduct its activities, both lawful and unlawful. Although the Scientology enterprise described WISE as a secular fraternal business association it is, in reality, one of the ten major Scientology activity sectors represented on Scientology's governing Watchdog Committee and is so indicated on the internal Scientology enterprise command chart.

24. Defendant Majestic Cruise Lines, was a division of the Foundation Church of Scientology Flagship Service Organization, is and at all relevant times was, a foreign corporation with a place of business at 118 North Fort Harrison Avenue, Clearwater, Florida and which also transacted business within the City of Los Angeles, County of Los Angeles, State of California.

25. Defendant M.V. Freewinds is, and at all relevant times was, a foreign registered motor vessel owned and operated by Majestic Cruise Lines by and, on behalf of Defendants. The M.V. Freewinds generally operates from various Caribbean ports and in international waters. It is believed to be a vessel that does not comply with many applicable regulations concerning seaworthiness and properly qualified and experienced crews. Thus, activities on the ship are outside of the jurisdiction of the United States government. Large quantities of semi-automatic and military assault weapons are kept on board and are inspected from time to time by Mexican authorities and other regional governments. The M.V. Freewinds also houses those certain Scientologists of senior stature, and who have been engaged in activities, that require them to be removed from law enforcement or civil jurisdiction, and are either on the RPF or being held in armed protective custody in furtherance of various Scientology schemes to obstruct justice. Recently, it appears that the Defendants have engaged in a number of sham ownership and leasing transfers intended to obstruct justice and to safeguard the M.V. Freewinds from attachment and arrest in this litigation.

26. Defendant International Association of Scientologists ("IAS") is, and at all relevant times was, a corporation having its principal place of business in care of St. Hill Manor, East Grinstead, Sussex, England, but which also did business within the City of Los Angeles, County of Los Angeles, State of California.

27. Defendant Church of Scientology, Flag Service Organization ("FSO") is, and at all relevant times was, a Florida corporation with its principal office in the City of Clearwater, State of Florida, but which did business within the City of Los Angeles, County of Los Angeles, State of California. For example, FSO solicits heavily in California and conducts substantial business in California. At one point, FSO was a division of CSC; subsequently, as part of Captain Miscavige's MCCS, it was spun off as an individual corporation and its assets transferred, without consideration, to avoid credit-worthy litigants' claims such as those of judgment creditor Lawrence Wollersheim and plaintiff herein. FSO also maintains facilities, such as "The Hacienda", the Q.I. Hotel, and the Sand Castle Hotel, in Clearwater, Florida where other Scientology 'Rehabilitation Project Force', or gulag/ concentration camp-style facilities are located, and other facilities where armed, patrolling guards are clearly visible to Scientologists and others including Scientology school children.

28. Defendant Flagship Service Organization, aka FSSO, Freewinds Relay Office, is, and at all times was, a Florida corporation with its principal office in the City of Clearwater, Florida, but which does business within the City of Los Angeles, County of Los Angeles, State of California.

29. Defendant Building Management Services is a California non-profit religious corporation, with its principal offices in the City of Los Angeles, County of Los Angeles, State of California, which has used monies contributed by Plaintiff to purchase properties in which some of the conduct complained of herein has occurred. Building Management Services is a low profile corporation holding major Scientology-owned real estate, as part of "Mission Corporate Category Sort-out" and the plan to ensure that any judgment creditors of the Scientology enterprise are unable to effectively collect and satisfy upon such civil judgments.

30. Defendant Church of Scientology of Paris is, and at all relevant times was, a French corporation with its principal office in the City of Paris, France, but which does business within the City of Los Angeles, County of Los Angeles, State of California. Church of Scientology of Paris is one of the French Scientology corporations. In 1996, the former head of the French Scientology enterprise, Jean-Jacques Mazier, was convicted of fraud and second degree murder, along with 13 other Scientologists, in connection with the death of a French Scientologist who committed suicide after being unable to endure the Scientology enterprise's pressure for more money, more money and yet more money any longer.

31. Defendant Church of Scientology Celebrity Center International is, and at all relevant times was, a California corporation with its principal office in the City of Los Angeles, County of Los Angeles, State of California.

32. Defendant Church of Scientology Celebrity Center Paris is, and at all relevant times was, a French corporation with its principal place of business in Paris, France, but which does business within the City of Los Angeles, County of Los Angeles, State of California.

33. Defendant Mary Sue Hubbard ("MSH") is a resident of the City of Los Angeles, County of Los Angeles, State of California. Until his death, allegedly on January 24, 1986, Commodore L. Ron Hubbard exercised dominion and control over all Scientology corporations through, until 1981, the Guardian's Office ("GO") which organization was headed by his wife MSH. Upon information and belief, MSH has converted millions of dollars of Church of Scientology funds, partially contributed to by Plaintiff, she has fraudulently taken or "culled" information from "PC files" to be used for purposes of blackmail and extortion and made an agreement, under fraud, duress and undue influence, with Norman Starkey as Executor, to waive her rights to her community property share of the Estate of L. Ron Hubbard. Between the latter part of 1979 and mid-1980, MSH was one of the 11 highest officials of the GO who were convicted of a variety of serious crimes by the United States Government, some of which are described in a 286 page "Stipulation of Evidence filed in United States v. Mary Sue Hubbard, Crim. Case No. 78-401 (D.C.D.C. 1978) and executed by MSH. Said "Stipulation of Evidence" is a detailed stipulation of the operation of the G.O. (now O.S.A.) to destroy some of the enemies of Scientology, one of which was the United States Government itself. These crimes were discovered in the course of the largest-ever raids conducted by the F.B.I. and they constituted the most extensive clandestine infiltration of the United States Government ever known. In mid-1980, in a deceptive "putsch" or take-over, involving misrepresentations by Captain Miscavige to Commodore L. Ron Hubbard, Captain Miscavige removed MSH as the "Controller" of the Guardian's Office, and Captain Miscavige now has MSH under virtual house arrest in the Hollywood Hills of Los Angeles, California. Plaintiff is informed and believes that had Defendants not entered into the 263 page "Stipulation of Evidence" in United States v. Hubbard, 474 F.Supp. 64 (1979), with the predecessors of the various Relief Defendants named herein, then certain of the Relief Defendants, such as the Government of the United States of America, would have publicly revealed certain additional evidence of the following: Defendants' extensive infiltration of the United States Government, and through the United States' electronic monitoring of encrypted and/or coded foreign diplomatic communications, the recruiting of senior government officials into the Scientology "religion," the using the 'auditing' and/or "confessional" or "sec check" processes to obtain classified information regarding, inter alia; international currency and commodity price movements from certain recruited government officials, and Defendant's conduct of paid intelligence operations in the United States on behalf of foreign governments, and then employing said knowledge to the financial benefit of the Defendants and at the expense, cost and detriment of Plaintiff generally.

34. Defendant Pat Broeker is an individual whose current whereabouts are unknown to Plaintiff, but understood to be known to Defendant Captain Miscavige and his hired "investigator" , intimidator and enforcer, former LAPD officer Eugene Ingram, who himself is the subject of numerous arrest warrants in various of these United States and abroad, and many of the other individual Defendants herein. Until Commodore Hubbard's death, allegedly on January 24, 1986, Defendant Pat Broeker was in hiding with Commodore Hubbard and communicated Commodore Hubbard's orders to Captain Miscavige. At that time, Plaintiff is informed and believes that Pat Broeker and Captain Miscavige together improperly controlled approximately $150 million of Scientology Enterprise monies which included monies which were contributed by Plaintiff, or which were the product of his labor, without authority to do so. Defendant Pat Broeker was Commodore Hubbard's designated successor until Captain Miscavige engineered a "putsch" or take-over to remove him and to confine him at one of Defendants' RPFs' or concentration camps, in Riverside County, California before allowing him to disappear into monitored obscurity and non-contactability. Defendant Pat Broeker committed tortious and other wrongful acts against Plaintiff while domiciled here.

35. Defendant Anne Broeker is, and at all relevant times was, a California resident and admitted tortious and other acts against Plaintiff while domiciled here in California. She is currently believed to be residing, under armed guard, at Scientology's base at Gilman Hot Springs near Hemet, County of Riverside, State of California. Upon information and belief, Anne Broeker escaped from said Scientology base, described in the court sealed declaration of Andre Tabayoyan (which is available on the Internet) as being "heavily armed and dangerous" and was allegedly captured and kidnapped (by Lieutenant Rathbun using a plane owned by Defendant John Travolta, and is now allegedly being held against her will at said Scientology desert base which also accommodates the Rehabilitation Project Force ("RPF"), described by many former Scientologists as a form of "gulag" or "concentration camp." Until Commodore Hubbard's death, allegedly on January 24, 1986, Ann Broeker was in hiding with Commodore Hubbard and assisted Pat Broeker to communicate Commodore Hubbard's orders to Captain Miscavige.

36. Defendant Lyman Spurlock, is a subordinate of Captain Miscavige, who is currently in charge of all of Church of Scientology finances and assets throughout the world. Spurlock, together with Captain Miscavige and Starkey, wrongfully controls Scientology assets, comprising monies contributed by Plaintiff, through various Scientology corporate shells and corporate mazes. At various times since 1981, Spurlock has been "Director of Legal Affairs" for ASI and RTC and he directed and coordinated the creation of most of the Defendant corporations that took place within Scientology in 1981 and 1982. " Prior to 1981, Spurlock held numerous other high ranking positions within Scientology and he is a member of the Sea Org. Defendant Spurlock is also one of the four co-founders of Church of Spiritual Technology doing business as L. Ron Hubbard Library and which has ultimate power over the entire domain of all Scientology-related entities, individual side projects and businesses owned by individual Scientologists.

37. Defendant Terri Gamboa, is a resident of the State of Arizona but, at certain relevant times, was a California resident and subordinate of Miscavige in which capacity, she received orders and directions from DM and through ASI, exercised wrongful control and dominion over assets of Scientology which included monies contributed by Plaintiff. She committed tortious and other acts against Plaintiff while she was domiciled in California. She is now subject to intimidation, by Defendants, intended to keep her forever silent about the matters set forth herein.

38. Defendant Mark Fisher is a resident of the State of Arizona but, at relevant times, was a California resident and a subordinate or "junior" of Captain Miscavige in which capacity he received orders and directions from Captain Miscavige and participated in the wrongful control and dominion over assets of the Scientology enterprise comprised, in part, of monies contributed by Plaintiff. He committed tortious and other wrongful acts against the Plaintiff while domiciled here in California. He is now subject to intimidation, by Defendants, intended to keep him forever silent about the matters set forth herein.

39. Defendant Vicki Aznaran is a resident of the City of Dallas in the State of Texas but, at certain relevant times, was a corporate officer of RTC who exercised wrongful control and dominion over assets of Scientology comprised, in part, of monies contributed by Plaintiff. Subsequently, along with Jesse Prince, she was imprisoned under armed guard at one of the Scientology `gulags' located in the California desert. She is now subject to intimidation, and a "gag" agreement by Defendants, intended to keep her forever silent about the matters set forth herein. She committed tortious and wrongful acts against the Plaintiff while domiciled here in California.

40. Defendant Mark or "Marty" Rathbun is either a resident of the State of California and/or does business within the State of California and at all relevant times was a subordinate or "junior" of Captain Miscavige, exercising wrongful control and dominion over assets of Scientology partially comprised of contributions by Plaintiff and engaged in fraudulent conduct directed at Plaintiff. Currently, Defendant Rathbun holds the rank of Lieutenant in the Sea Org and occupies the post of Inspector General Religious Technology Center. In or about late 1993/early 1994, Defendant Rathbun "blew his post", left Scientology and was later "returned" and held captive at sea aboard the M.V. Freewinds while he was being re-educated and "rehabilitated".

41. Defendant Michael Rinder was formerly an Australian citizen and resident, who has at material times occupied the `Post' and worn the `Hat' of Commanding Officer, Office of Special Affairs (C.O. O.S.A.) As such he commands the litigation harassment, intimidation and intelligence gathering operations of the Scientology Enterprise. Defendant Rinder is now a resident of the State of California and conducts business in the City of Hollywood California. Defendant Rinder personally met with Plaintiff and had participated, with Scientology attorneys Elliot Abelson and William Drescher, in the perpetration of the various criminal and tortious conduct alleged herein. He has also participated in the suborning of perjury, and attempted obstruction of justice, from persons such as Vicki Azneran, Richard Azneran, R. Vaughn Young, Stacey Young, Andre Tabayoyan, Robert F. Lewis, Esq. and Garry Scarff.

42. Defendant Ray Mithoff is, and at all relevant times was, a resident of the State of California and a subordinate of LRH, MSH and Captain Miscavige and currently holds the rank of Commander in the Sea Org and the post of Senior Case Supervisor (C/S) International. At various times, notwithstanding his alleged former illicit hallucinogenic drug activity, he was RTC Inspector General Tech and participated in various of the frauds perpetrated upon Plaintiff. He is also believed to maintain a secret list of "mysterious" Scientology related deaths believed in some way, inter alia, to be connected to the unlawful practice of medicine using the E-meter.

43. Defendant Heber Jentzch is a resident of the City of Los Angeles, County of Los Angeles, State of California, a former actor and comic, and since 1983 has been the President of CSI. As President of CSI and as the principal public relations spokesperson for Scientology, he has participated in the various fraudulent representations perpetrated upon the Plaintiff. In November 1988, Rev. Jentzch was arrested in Spain and held in jail for 30 days on charges of fraud, forgery, kidnapping, coercion, failure to meet Social Security payments and illegal association. Rev. Jentzch fraudulently engineered his release upon $1 million bail and he is still awaiting trial. If convicted, he faces a possible sentence of sixty (60) years in a Spanish prison.

44. Defendant Danny Keogh is a resident of the State of Florida who has minimum contact with the State of California. He has participated in the various fraudulent representations and misconduct perpetrated upon the Plaintiff. Defendant Keogh is the former husband and reported current lover of Scientologist Lisa Marie Presley. Upon information and belief, Defendant Keogh and Lisa Marie Presley were divorced, "for the greater good of scientology" and "the greatest number of dynamics", so that she could try and recruit singer Michael Jackson into Scientology, and to that end Scientology operatives assisted in the "handling" of the various pedophilia investigations being conducted into Mr. Jackson at that time.

45. Defendant Jacqueline Van Der Linde (Govan) is a resident of the City of Clearwater, Florida, a field staff member of Defendants, and was at one time was a member of the Guardian's Office and at the orders of Commodore Hubbard and certain of the other Defendants herein participated in the instructions to Plaintiff to lie about the Scientology presence in, and intended takeover of, the City of Clearwater by masquerading as members of the United Churches of Florida as more fully described herein. She has "minimum contacts" with the State of California.

46. Defendant Mary Voegeding is the President of Flag Land Base at Clearwater, Florida and is a person who personally participated in the fraudulent and unlawful conduct perpetrated upon the Plaintiff. She has "minimum contact" with the State of California.

47. Defendant Alain Franck Rosenberg is the Executive Director of Celebrity Center Paris, one of the Defendants herein, who does business within the State of California and who participated in the perpetration of the various fraudulent and wrongful conduct Defendants perpetrated upon Plaintiff herein. He has both minimum contacts "with the State of California" and "national contacts" with these United States.

48. Defendant Guillaume Lesevre is the Executive Director of CSI (ED Int.) and in that capacity is the Executive Director of the Scientology Enterprise worldwide. The "post" or "hat" of ED Int was once held by Hubbard. As one of the most senior staff members of the Scientology Enterprise he has participated in the fraudulent, tortious and other wrongful conduct that Defendants have perpetrated upon the Plaintiff herein. Defendant Lesevre also holds the rank of Captain in the Sea Org. In addition, Defendant Lesevre and Plaintiff had personal and direct communication on the issue of resolving the injustice perpetrated upon him, as more fully described herein, and the restoration of the OT levels wrongfully stripped from Plaintiff after he had paid over $500,000 dollars to obtain those same OT levels. Thus, Defendant Lesevre has unique percipient knowledge of the matters complained of herein.

49. Defendant Sarit Rosenberg is the President of Celebrity Center Paris which does business among other places, in the City of Los Angeles, County of Los Angeles, State of California and who personally participated in some of the most egregious of the tortious and wrongful conduct perpetrated by Defendants upon Plaintiff. She has "minimum contacts" with the State of California and "national contacts" within these United States.

50. Defendant John Travolta ("Travolta"), at various relevant times herein, was a resident of the City of Los Angeles, County of Los Angeles, State of California. Furthermore, he has committed tortious acts against Plaintiff while domiciled in California. Defendant Travolta is a "celebrity member" of the Church of Scientology. He has also been a member of Scientology for a period of time similar to that of Plaintiff. Defendant Travolta has been a prolific, principal public spokesperson and recruiter for the Church of Scientology, owing fiduciary duties to his fellow Scientologists, making statements, now known to be material misrepresentations, which Plaintiff reasonably relied upon to his detriment. Said misrepresentations continued until the time Plaintiff ceased Scientology training and auditing. Defendant Travolta has also helped to lure young actors and actors through the Celebrity Center and into Scientology using the heavily Scientology staffed Beverly Hills Playhouse as a recruitment vehicle. Because Plaintiff had been lured into Scientology upon, among other things, the representation that Scientology counseling and courses would "handle" or cure his homosexuality or "ruin", Plaintiff relied, to his detriment, upon Defendant Travolta's public statements as a spokesperson for Defendants, endorsing Scientology and the practices of Defendants. More recently, as part of what has been called "Cult-Gate", Defendant Travolta has reportedly been responsible for subverting the President of the United States into intervening, through the United States' Secretary of State and the National Security Advisor, in the internal affairs of the Government of Germany and, through the United States' Department of Commerce and the United States' Trade Negotiator, in the internal affairs of the Government of Sweden by placing it on a 301 Watch List with associated threats of United States' Government's Trade Sanctions against the Government of Sweden for refusing to comply with Defendants' demands, and the Clinton Administration's Demands, concerning public availability of scriptures allegedly relating to their so-called religion. Indeed, Defendant Travolta has stated "I found Washington fascinating, like a puzzle. If you know it well enough, you can infiltrate and get things done. We got tons done."(emphasis added) Thus, Defendant Travolta has knowingly participated in the intentional violation of the Establishment Clause of the First Amendment to the United States Constitution, thus instigating the "excessive entanglement of church and state." Defendant Travolta has known of Scientology's "gulags" and "concentration camps, otherwise known as RPF's, through both personal observation and information received from a certain former Scientologist, but has deliberately chosen to turn a blind eye to their existence and to refrain from disclosing his knowledge to people such as Plaintiff who trusted and relied upon him as a principal spokesperson on behalf of the Defendants. Indeed, when the movie "Saturday Night Fever" was first released, he knowingly arranged for a hard to obtain copy of the movie to be shown to members of the Sea Org sentenced to armed confinement in the RPF, or "gulag" in Scientology's buildings in Hollywood, California. Defendant Travolta's public statements, "handling" and subsequent marriage were material statements Plaintiff reasonably relied upon, as Commodore Hubbard intended when he taught Defendants how to "use" celebrities such as Defendant Travolta, for the recruitment, brainwashing and retention of the Plaintiff and others.

51. Defendant Jane Kember was at material times a resident of the State of California, has conducted business in the State of California, and whose last known place of residence was 24 Tennyson Rise, East Grinstead Sussex, U.K. Defendant Kember was one of the senior Scientologists convicted of the largest ever criminal infiltration of the United States Government. She has requisite "minimum" and "national contacts".

52. Defendant Captain Mark Yaeger is a resident of the City of Los Angeles, County of Los Angeles, State of California and C.O. "CMO Int." (Commanding Officer, Commodore's Messenger Organization International) and has participated in the conspiracy and other wrongful conduct herein alleged, including but not limited to the June through October, 1993 telex traffic concerning Plaintiff.

53. Defendant Wendell Reynolds is a resident of the City of Los Angeles, County of Los Angeles, State of California. In 1982 Defendant Captain Miscavige appointed him Head of the International Finance Police of the Scientology Enterprise.

54. Defendant Kendrick L. Moxon ("Moxon") is a resident of the City of Los Angeles, County of Los Angeles, State of California and was a Deputy Guardian engaged (as an unindicted co-conspirator) in the vast Scientology criminal activities leading to the arrest and imprisonment of certain senior Scientologists in Washington, D.C. and elsewhere, for the largest ever known criminal infiltration of the United States Government, in which capacity he has been responsible for, or participated in, various of the criminal, fraudulent and unethical activities alleged herein and either directed at, or damaging to the Defendant. Moxon is employed within the Office of Special Affairs as an attorney although he has variously held himself out as an attorney with the law firms of Bowles & Moxon, Moxon & Bartilson and Moxon & Kobrin. The Office of Special Affairs, in addition to handling legal matters in accordance with Scientology policies of abusing the legal system, has, since the closing of the Guardians Office, controlled and directed many of Scientology's covert intelligence gathering and harassment operations. Defendant Moxon conceived the Bowles & Moxon Plan 100 to destroy IRS ? 501(c)(3) organization the "Cult Awareness Network", filed over 50 meritless lawsuites intended to and which did, bankrupt it completely, and directed and participated in various of the human rights violations, civil rights violations abuses and abuses of the legal and judicial system alleged herein.

55. Plaintiff is ignorant of the true names and capacities of Defendants, Does 1 through 10, and therefore sues said Defendants by fictitious names. Plaintiff will seek leave to amend this complaint when the true names of said Defendants have been ascertained. Plaintiff is informed and believes and on that basis alleges that each of the fictitious Defendants was in some way responsible for, participated in or contributed to the matters and things of which Plaintiff complains herein and, in some fashion, has legal responsibility therefore.

56. The designation of any Scientology entity, including Defendants herein, as a church and/or non-profit entity is a fraudulent sham. It is designed to exploit the protection of the First Amendment, to obtain tax exemptions and to prevent the regulation of Scientology "counselors" or "counseling techniques" by state regulatory agencies. The religious claims also serve Defendants' commercial public relations ("PR") purposes. Commodore Hubbard and his successors, including the Defendants herein, have profited and benefited from the income, perks and power of Scientology, and the labor and financial contributions of Plaintiff herein. The Scientology enterprise sells written materials and purported psychological counseling, Scientology services and Scientology auditing at a huge profit, and to its unjust enrichment, at the expense of Plaintiff. Accordingly, whenever the reference to Scientology as a religion and its entities as "churches" is made herein, it should not be construed as Plaintiff's acquiescence in those designations, but is rather used, on occasion, to aid in the clarification of the different entities involved in the fraud perpetrated by the Defendants herein, on behalf of the Scientology enterprise, upon the Plaintiff.

57. Defendants are part of an ongoing criminal enterprise, and criminal association in fact, referred to herein as the SCIENTOLOGY enterprise. The persons in control of this criminal enterprise are members of controlling groups such as the "Sea Org," the "Office for Special Affairs" ("OSA"), "Approval Lines" and "The Commodore's Messenger Org" ("CMO"). At all relevant times, the corporate Defendants, the unincorporated Defendants, the individual Defendants and the Sea Org have conducted and been engaged in the promulgation and sale of the writings and practices of L. Ron Hubbard and Scientology as a unified business enterprise.

58. The various corporate Defendants herein are co-conspirators subject to a unity of control. The separate alleged corporate structures were created as part of a scheme to avoid liability for the acts of the enterprise, including the avoidance of taxes, civil judgments and criminal penalties. Because of the unity of control, unity of personnel, overlapping boards of directors, overlapping executives, overlapping attorneys, including some from the nation's most prestigious law firms, commingling of assets, and commonality of business objectives, the attempt at separation of these corporations, and other entities, and all of Scientology's other corporations and entities, should be disregarded by the court. In particular, there exists, and at all times relevant hereto, has existed, such a unity of control and interest among the corporate Defendants, and the Sea Org, such that any individuality and separateness between each of them has ceased and each is the alter-ego or agent of the others in that, among other things:

59. Adherence to the fiction of the separate existence of the Defendant corporations and of the Sea Org would permit an abuse of corporate privilege and would promote injustice in that, via the unified control, the assets of the corporate Defendants and Sea Org can be transferred at will and, thus, concealed from corporate debts, liabilities, government obligations and taxes and other obligations. Adherence to the fiction of the separate existence of the Defendant corporations and the Sea Org would also be inequitable because the Managing Agents and/or subdivisions of the Scientology enterprise can transfer personnel and control of documents from one entity to another, thus allowing the Defendants to avoid legitimate discovery and thereby to effect the continuing abuse of process, obstruction of justice, manipulation of the judicial system, improper and unlawful manipulation of the political system and of the government, and caused the unconstitutional and excessive entanglement of Church and State, including but not limited to numerous officials within the Clinton Administration, the President of the United States and his National Security Advisor Sandy Berger. Defendants have also subverted various and sundry other government officials, including but not limited to officials of the United States Internal Revenue Service, (`Scientology's Puzzling Journey From Tax Rebel to Tax Exempt'. Douglas Frantz, New York Times, Sunday, March 9, 1997), Exhibit "D", to the furtherance of their unlawful, criminal, fraudulent activities, and subversive totalitarian objectives.

60. In addition, Defendants have engaged in the furtherance of their criminal and fraudulent conspiracy to establish their totalitarian anti-democratic beliefs upon all persons within the world by recruiting and subverting the new Prime Minister of Russia, attempting to take over other governments such as those of former Rhodesia and certain Mediterranean Islands, and otherwise suborning every potential "terminal" capable of being used to further the anti-democratic, anti-social, criminal and fraudulent beliefs and activities of Defendants and all those associated with, or assisting them, such as "celebrity members" Tom Cruise and Nicole Kidman.

61. At all relevant times mentioned herein, each of the Defendants was the co-conspirator, "senior," "junior," partner, agent or employee of the other acting within the course and scope of that agency, employment or conspiracy and did the acts herein, or participated in some way in the acts alleged herein, pursuant to said relationship. Specifically, all named Defendants are the agents, partners, joint venturers and/or conspirators of each other Defendant and they should all be liable for the acts of the others.

62. Alternatively, at all times herein mentioned, each of the Defendants and/or their predecessors, affiliates, subsidiaries and related entities, and each of the Doe Defendants, was the agent, servant, employee, fellow member, associate and/or joint venturer or conspirator of each of the other remaining Defendants and was at all times acting within the purpose and scope of said agency, employment or joint venture, and acting with the express and/or implied knowledge or consent of the remaining Defendants, and each of them. The acts of each Defendant were approved and/or ratified by each other Defendant and, together, constitute a single course of conduct.

63. At all times mentioned herein, each and every Defendant was the authorized agent, servant and/or employee of each and every other Defendant and was acting within the scope of his/her authority as agents, servants and employees with the permission and consent of their co-Defendants. Reference to "Defendants" shall mean Defendants and each of them.

64. The Managing Agents of Scientology currently include Captain David Miscavige, Lieutenant Marty Rathbun and Norman Starkey, who operate through divisions known as the Sea Org, the "Watchdog Committee," and an elite organization of aides known as the "Commodore's Messengers" ("CMO"). Before his death in 1986, Commodore L. Ron Hubbard was also one of the Managing Agents and, at various times, so also have Defendants Pat Broeker, Mary Sue Hubbard, Terri Gamboa, Mark Fisher and Vicki Aznaran been Managing Agents of the Scientology enterprise.

65. Each of the individual, corporate and other entity Defendants, and Does 1 through 10, are or have been principal officers or controllers, or both, of all of Defendant corporations listed herein. There exists a unity of interest in ownership between the individual Defendants listed above and the corporate Defendants listed above. Any individuality and separateness between the individual Defendants and the corporate Defendants has ceased. The individual Defendants are alter-egos of the corporate Defendants and vice-versa, and the corporate Defendants are mere shells, instrumentalities and conduits through which the individual Defendants have transacted business with the Plaintiff to such an extent that the corporate entities do not exist. Adherence to the fiction of the existence of the corporate Defendants as entities distinct from the individual Defendants would work a fraud, promote injustice, or both.

66. The acts and conduct of Defendants, and each of them, as hereinafter set forth, are continuing and are part of a massive international conspiracy originated, agreed to, orchestrated and accomplished by Defendants, and each of them, to carry out the events and circumstances as herein alleged with a total disregard for the constitutional, civil, human and contractual rights of Plaintiff, to damage Plaintiff, and to cheat Plaintiff out of his money, property, services and information.

67. The acts complained of herein were variously authorized by Commodore L. Ron Hubbard, Pat Broeker, Captain Miscavige, and the other Defendants, prior to their occurrence or ratified after the fact by their representatives and/or the Defendants, and each of them, named herein.

68. The individual Defendants named herein have been variously subordinates or "juniors" of Commodore L. Ron Hubbard, Pat Broeker and Captain Miscavige and have assisted each of them, and others, in wrongfully controlling Church of Scientology assets, consisting at least in part of moneys contributed by Plaintiff, through various corporations such the corporate and associational Defendants herein.

69. The corporations named herein were formed, among other things, for the purpose of creating a corporate maze through which those in control of Scientology could and did channel church monies, and Plaintiff's monies, through individuals and entities such as Defendant Religious Research Foundation, into Commodore L. Ron Hubbard's personal accounts, and the accounts of others, and for the purpose of divesting the Church of Scientology of California, and other entities, of their assets as part of a criminal and fraudulent conspiracy directed at the Plaintiff, other members of the Church of Scientology, judgment creditors of various of the Churches of Scientology, (such as judgment creditor Lawrence D. Wollersheim, LASC Case No. C132027), the United States Government, other national governments, and their citizens generally.

70. Plaintiff is informed and believes and based thereon alleges as follows: The Church of Scientology was founded by L. Ron Hubbard ("Hubbard, Commodore Hubbard or LRH") in or about 1952 and after reportedly saying "I want to form a religion, that's where the real money is". Previously, L. Ron Hubbard's Dianetic training had been promoted as a secular form of mental health counseling. After scathing denunciation by the mental health profession, Commodore Hubbard declared "war on the psychs" and, through "front groups" such as Citizen's Commission on Human Rights '(C.C.H.R."), the Scientology war to destroy the mental health professional continues today. Between 1952 and January 1986, after an initial bankruptcy and shareholder disputes, the Scientology enterprise grew into many different corporations worldwide, all of which were totally dominated and controlled by Commodore L. Ron Hubbard and Defendant Pat Broeker, during said period and are now dominated and controlled by Defendant Captain Miscavige. Commodore Hubbard exercised complete dominion over said Scientology corporations by requiring the officers and directors of each corporation to sign a written resignation in advance of their assuming the position, and Commodore Hubbard held said resignations, removing officers and directors of the various corporations at will throughout the period from early 1952 until January 1986, Commodore Hubbard has been held to be the "alter ego" of the Church of Scientology in the case of Church of Scientology v. Armstrong, Los Angeles Superior Court No. C420 153; Defendant Captain Miscavige has been held to be the successor "alter ego" of the Church of Scientology in the case of California v. Wollersheim v. Church of Scientology, LASC Case No. C332027.

71. All of the Defendants herein named are part of the Scientology enterprise, which is in the business of promulgating and selling the system of practices and beliefs espoused by Commodore L. Ron Hubbard and the Church of Scientology. Scientology is a pseudo-scientific system which claims to be a "scientifically proven" study of the human mind and of society. In claiming to provide "scientifically proven" cures, Defendants have waived the right to make claims based upon "religous faith". In reality Scientology is a vast commercial enterprise with totalitarian political objectives to take over and rule, or "clear", the entire Planet Earth. Scientology is also promoted as, and masquerades as, a religious system that is marketed and sold through a series of expensive courses, and counseling sessions called "auditing". Numerous claims for the "curative" effects of Dianetics and Scientology were made by the science-fiction writer and the founder of Scientology, and Commodore L. Ron Hubbard, and have continued to be made by the Defendants who promote that system and exploit Commodore Hubbard's "scientifically proven" "technology." These claims include the promise that Scientology will improve one's IQ, will cure a person of his/her physical ailments (Hubbard claimed to have cured himself from blindness and war-time gunshot wounds to the back), will ensure one's physical health and well-being, will improve one's business and personal relationships, making it possible to achieve anything one wants to achieve and, among other things, will cure persons of their homosexuality, notwithstanding Defendants' alleged copyrights containing writings calling for the extermination of homosexuals; such persons also being labeled as covertly hostile or "1. 1" on Hubbard's Tone Scale, as set forth in The Science of Survival. Such persons are described in The Science of Survival, as being the most dangerously insane people in society, and likely to cause the most damage, and who should not have any civil rights of any kind, and who should be quarantined and exterminated, just as Nazi Germany did to the Jews and Stalin did to Soviet "dissidents", along with 2-1/2% of the rest of the world's population who are said to be truly dangerous and "anti-social" as described in An Introduction to Scientology Ethics when, Scientology "clears the planet" and achieves world-wide domination and control of all politicians, governments, business entities and individuals as set forth herein. The Defendants had intended to "Clear the Planet" by the year 2000 but this plan currently appears behind schedule.

72. The business of Scientology, and the RICO enterprise of Scientology as alleged herein, and of the Defendants herein, whether for profit or nominally not for profit, is the marketing and selling of Dianetics; Scientology: A World Religion Emerges In The Space Age; The Science of Survival; The Second Dynamic, (a compilation by Cass Warner Poole and published under Commodore Hubbard's name before being withdrawn from the market, which Plaintiff read and upon which he reasonably relied to his detriment), and other books, tapes and services associated with Hubbard and the Scientology enterprise (most of which plaintiff read and upon which he reasonably relied); profiting from such sales; promoting the personality of Commodore Hubbard and his successors such as Captain Miscavige; and marketing the extraordinarily expensive and never-ending Scientology courses and counseling sessions by using fraudulent guarantees of improved intelligence, health and well being. Through these counseling sessions, personal secrets are divulged in a confessional fashion, and mind control techniques, coercive manipulation and coercive indoctrination techniques, hypnotic techniques and brain-washing techniques, including those Commodore Hubbard refers to in his thesis on "Brain-Washing," are utilized, which entrap people, and specifically entrapped the Plaintiff herein, into spending even more money on more and never ending expensive courses, auditing and materials, all delivered according to Scientology's "Doctrine of Exchange" which inter alia, provides that the "fixed donation" of "money" must be exchanged before one can ever learn any of the so-called truths or tenets of Scientology as scientifically "discovered" by Commodore L. Ron Hubbard. In many instances, these counseling sessions persuade the victims of Scientology to desert their families, turning the victims into androids, commonly referred to as "Rondroids", for Scientology.

73. Persons who become Scientology androids by joining the staff of the many subordinate organizations of Scientology are subjected to further degradation for failure to meet goals set for them on courses, in clerical jobs, and doing menial tasks. The "religious" or non-religious nature of the tasks re irrelevant. Such degradation may include being ordered into the Rehabilitation Project Force (the "RPF"), or the RPF's RPF, which entails imprisonment at secret Scientology facilities, sleep deprivation, food deprivation, and physical punishment, e.g. , being thrown off ocean-going vessels blindfolded, being forced to run for 12 hours a day with only ten minute breaks, once per hour, wearing rags, eating leftover scraps, being spat at, being subjected to hours of intense interrogation called "security checking", being housed in facilities that have included chicken coops, and being forced to sign false affidavits accusing oneself of improper conduct while releasing Scientology from any liability for this type of alleged `voluntary' treatment and coercive indoctrination.

74. Among the most important and fundamental Scientology concepts which helps to explain the institutional abuse to which members, most particularly staff members, are routinely subjected is delineated by the underlying assumption that people are "acting out" the behavior of those they define as being the most successful (i.e. , the "winning valance.")

75. According to the Dianetics and Scientology Technical Dictionary "valence" and "winning valence" are defined as: somebody else's identity assumed by a person unknowingly. 2.  the valence mechanism produces whole people . . . and will include habits and mannerisms which are . . . a result of the preclear's [person's] compulsion to copy certain people." Winning valence is defined as: "WINNING VALENCE. . . 2. in the case of the woman beaten by her husband, the engram [painful incident] contains just two valences. Who won? The husband. Therefore . . . the thing to do is be the winner, the husband, to talk like him, to say what he did. Hence, . . . she dramatizes [acts out] the winning valence." (emphasis in the original).

76. Accordingly, Plaintiff is informed and believes that Scientology's founder, Commodore Hubbard, was notorious for his astoundingly verbally abusive as well as physically punishing behavior. Following his power struggle with the Broekers, subsequent to Commodore Hubbard's death in 1986, Captain Miscavige emerged as the "winner" displaying precisely the same personality traits ("dramatizing the winning valence") as those exhibited by Commodore Hubbard himself. In fact, all of the highest level Scientology enterprise officials with whom Plaintiff has had contact have, amazingly, displayed this negative, abusive, punishing, ranting behavior, particularly when frustrated by their inability to get "stats" up or keep control over a situation.

77. Captain Miscavige, Heber Jentzsch, Kendrick Moxon, Michael Rinder, Sarit Rosenberg, et al., are all daily reflecting ("dramatizing") Commodore Hubbard's basic personality which has been described by Judge Paul Breckenridge of the Los Angeles Superior Court as "schizophrenic and paranoid".

78. The "schizophrenic and paranoid" Hubbard systematically abused the people around him. Those who have followed in his footsteps have been continuing the reign of abuse and terror, even if unconsciously, by "dramatizing" the "winning valence" which, in this case, was unfortunately Commodore Hubbard's. Even more shocking to normal people is the fact that Commodore Hubbard's aberrant personality is considered to be the ideal "beingness" within the Scientology organization. Each decision is predicated on the question "what would Ron do under the circumstances?" Each person loses his own personality by subsuming it to the fraudulent Hubbardian ideal in order to avoid being ostracized by his fellow Scientologists.

79. Once a person who has fallen under this criminal enterprise scheme called Scientology, seeks to disassociate from it or rebels, Scientology uses the various techniques described herein as well as threat of disclosure of the privileged information in confessional files to blackmail and control such potential traitors. If such a person is not dissuaded from leaving Scientology, such treatment continues until the person is willing, under duress, to sign false affidavits accusing himself or herself of various crimes and improper acts and to sign a release of all claims against Scientology. Failure to execute such documents before resigning from Scientology or leaving its control renders a person "fair game" as defined and described herein.

80. The recruiters for the Scientology enterprise, and for the Defendants named herein, used methods of mind control, hypnosis, coercion and deception upon Plaintiff. Commodore Hubbard once declared that Scientology operates and achieves its objectives via brainwashing. This declaration is part of "Scientology

"Scripture," in which Hubbard stated in Hubbard Technical Bulletin (22 July, 1965): "We know more about psychiatry than psychiatrists. We can brain-wash faster than the Russians."

81. Plaintiff is informed and believes and based thereon alleges as follows: Commodore L. Ron Hubbard also exercised complete dominion and control over all Scientology corporations through an organization called the "Guardian's Office," which organization was headed by Commodore Hubbard's wife, Mary Sue Hubbard, and which organization between 1966 and early 1981, was constituted the management organization, totally controlling all Church of Scientology funds and property; and that between the later part of 1979 and mid-1980, the eleven highest officials of the Guardian's Office, including Defendants Mary Sue Hubbard and Jane Kember (but not the unindicted conspirator Kendrick L. Moxon, Esq. of the Washington D.C. and California State Bars) were convicted of a variety of sedition and other crimes by the United States Government, which resulted in the incarceration of said individuals.

82. Plaintiff is informed and believes and based thereon alleges as follows: On or about March 1980, Commodore L. Ron Hubbard left the premises of the Church of Scientology in Hemet, California, and vanished; at the time Commodore Hubbard disappeared, there were pending Grand Juries in New York and elsewhere investigating alleged criminal activities by Commodore L. Ron Hubbard, Mary Sue Hubbard and the Guardian's Office. Commodore L. Ron Hubbard had previously been convicted of criminal fraud in California (1948) and in France (1973); also in the mid 1979's early 1980's, numerous and various individuals commenced dozens of lawsuits against Commodore L. Ron Commodore Hubbard and the Church of Scientology, alleging a variety of torts committed against them. In connection with Defendants' response, George T. Kattar was convicted of criminal conduct (U.S. v. Kattar, 840 F.2d 118 (1st Cir. 1988)). These lawsuits included Van Shaick v. Church of Scientology of California, Inc. , 535 F.Supp. 1125 (1982); Christofferson v. Church of Scientology, 57 Ore. 203, 644 P.2d 577 (1982); Allard v. Church of Scientology, 58 Cal.App.3d 439 (1976); Wollersheim v. Church of Scientology, 212 Cal.App.3d 872 (1989); Church of Scientology v. Armstrong, 232 Cal.App.3d 1060 (1991). Plaintiff's monies were used in connection with the defense of these lawsuits but Defendants concealed the details from Plaintiff. Had Plaintiff known the details of such lawsuits then he would have ended his exploitation by Defendants at that time.

83. As a result of the conviction and incarceration of the eleven highest members of the Church of Scientology, including Defendants MSH and Kember, and the disappearance of Commodore L. Ron Hubbard into hiding, between approximately early 1981 and until Commodore Hubbard's death, allegedly on January 26, 1986, there was continuous conflict and dispute over the management and control of monies and property of the Church of Scientology which comprised in part, monies, time and trust contributed by Plaintiff. Plaintiff alleges that the Defendants are currently controlling secret bank accounts around the world (including in Luxembourg and Switzerland), property and exercising dominion and control over various assets, which include monies contributed by Plaintiff and the product of his trust and labor as alleged throughout herein, without possessing the requisite corporate authority to do so, in violation of the charters of the various corporations, and in violation of applicable state, federal and other national law. Defendants acquired and have maintained control of said assets, by fraudulent acts and by criminal acts, perpetrated upon Plaintiff, as hereinafter set forth.

84. During the periods he was in seclusion, Commodore Hubbard would exercise his power by issuing a directive called 'Weekly Analysis' or by written directives authenticated by an asterisk meaning the author was Commodore Hubbard." Captain Miscavige would bring such directives to a regular weekly meeting of a small cadre of top Scientology individuals who would then adopt Commodore Hubbard's plans as their own and discuss plans to accomplish Commodore Hubbard's directives.

85. Plaintiff is informed and believes and based thereon alleges as follows: In approximately March 1980, upon the disappearance of Commodore L. Ron Hubbard, the assets and property of the Church of Scientology were not under the control of any Scientology corporation or its officers or directors. Although each Scientology corporation had a charter, a Board of Directors and officers, said charter, Board of Directors, and officers had no actual authority or control of any nature or description. In 1966, when Commodore Hubbard "purportedly" resigned his position as "Executive Director International" of all Churches of Scientology throughout the world, which was then the highest Scientology executive management post, he simultaneously created the "Guardian's Office," now OSA, as Department 20 on the Scientology Org. Board, and designated his wife, Mary Sue Hubbard, as "Controller" of all Scientology organizations throughout the world and over the Guardian's Office. Between 1966 and early 1981, Commodore L. Ron Hubbard, Mary Sue Hubbard, and the Guardian's Office exercised total control over all Church assets, bank accounts, property and trademarks including monies contributed by Plaintiff and the product of his trust and labor.

86. Plaintiff is informed and believes and based thereon alleges as follows: Prior to 1973, and continuing to the present, both before and after the indictment and conviction of Mary Sue Hubbard and other high-level Scientology officials (such as Jane Kember), Captain Miscavige, Pat Broeker, Anne Broeker, Norman Starkey, Vicki Aznaran, Terri Gamboa, Mark Fisher, Lyman Spurlock, gradually began to assume complete dominion and control over all Scientology assets and property throughout the world, although they received no corporate authority to do so. In early 1981, Commodore Hubbard, even though he held no official position in any Scientology corporation, allegedly authorized Captain Miscavige to take control of Church assets to the detriment of his designated successor Pat Broeker and with the assistance of monies and labor contributed by Plaintiff. At the same time, Commodore Hubbard appointed William Franks as "Executive Director International" and ordered Franks to become a signatory on certain bank accounts in Luxembourg containing approximately $150 million dollars. Although Franks held the highest official management position in the Church of Scientology, he received his daily orders from Captain Miscavige upon the representation that Commodore Hubbard was issuing daily dispatches containing orders which must be followed in the distribution of assets of the Church of Scientology. Franks himself was required to sign an undated letter of resignation as "Executive Director International."

87. Plaintiff is informed and believes and based thereon alleges as follows: Between June 1981 and December 1981, conflict developed between Captain Miscavige and Franks over control of Church bank accounts. In November 1981, Captain Miscavige had Franks physically locked up in a room for several weeks while Captain Miscavige assumed control of all Scientology corporate bank accounts, and other assets. Throughout this period, Captain Miscavige was represented by attorneys Sherman Lenske and John Peterson (now deceased) and Captain Miscavige paid them millions of dollars in attorneys' fees in connection with their assistance in achieving this unauthorized and illegal takeover, all without the knowledge and consent of Plaintiff but, at least in part, with monies that were the product of Plaintiff's financial contributions, trust and labor.

88. Plaintiff is informed and believes and based thereon alleges as follows: In early 1982, Sherman D. Lenske, Esq., on behalf of Defendants Captain Miscavige, Spurlock, Starkey and several others, incorporated ASI which became the corporate entity controlling Church of Scientology bank accounts and assets in violation of applicable law, rules, and regulations, and the representations of certain Defendants. In fact, the officers and directors of ASI, which included Captain Miscavige, Starkey and Spurlock, possessed no authority from any Church of Scientology corporation to control its bank accounts and property.

89. Plaintiff is informed and believes and based thereon alleges as follows: At the same time as the incorporation of ASI, Sherman D. Lenske, Esq. on behalf of Captain Miscavige, incorporated Religious Technology Center ("RTC") and Church of Spiritual Technology ("CST"). Between January 1982 and June 1982, Lenske represented ASI, RTC, CST, Commodore L. Ron Hubbard and various Scientology corporations in the fraudulent transfer of monies, property and assets from various Scientology corporations to Commodore L. Ron Hubbard personally. Lenske also prepared wills and inter vivos trusts on behalf of Commodore Hubbard, which were witnessed, among others, by Defendants Pat Broeker and Anne Broeker. Starkey (and therefore RTC became the trustee of said Trust(s). The assets of various Scientology corporations, which were taken over by ASI in 1982, included bank accounts, personal property, real property and current income of the various corporations and property which lawfully belonged to MSH and the children of LRH, but which Captain Miscavige procured with use of monies and labor fraudulently obtained from Plaintiff. The Charters of these corporations were violated in the take-over by ASI. The Charters of each corporation provided that the corporate affairs were to be regulated and managed by the Board of Directors of said corporations when, in fact, the various Boards of Directors of each Scientology corporation were illegally controlled by ASI, Captain Miscavige, Broeker and Commodore Hubbard. Prior to his death, allegedly in 1986, Commodore Hubbard personally managed, directed or through the other managing agents (such as Captain David Miscavige) and their subordinates, the entire Scientology enterprise, including the Defendants herein. His management design was to ignore the formal structure of the many entities and to operate them as his personal domain and he did so, and Defendant Captain Miscavige continues to do so today. The goal of this management technique was, first and foremost, to optimize Commodore Hubbard's personal income in violation of the prohibition against personal inurement imposed on institutions seeking charitable, religious, tax-exempt status under IRC Section 501(c)(3). This facade of independent corporations was created to make the structure of the Church more defensible to criminal investigation and civil liability while still being managed by the same unity of control under the direct command of Commodore Hubbard and his several top aides including Captain Miscavige, Starkey, Epstein and Spurlock.

90. This management maze also permits money to be shifted among entities to hide their profit-making reality and to avoid taxes and judgments. Furthermore, insofar as actual control of the entities was/is in the hands of individuals who are not within the formal corporate structure, the conduct of affairs of each of the several entities could be kept secretive.

91. In or about October of 1982, certain of the Defendants, including Captain Miscavige conspired to steal millions of dollars from lower level Scientology missions or franchises and persons including the Plaintiff. This was done by requiring the franchise ("Mission") holders to attend a meeting ("the Mission Holders Meeting") in Clearwater, Florida, and San Francisco, California where they were intimidated, "overwhelmed" and defrauded, and utilizing the monies, forced donations, trust and labor of Plaintiff in the process but without the knowledge and consent of the Plaintiff. Among other things, 600 persons were declared "Suppressive Persons" and their assets and livelihoods confiscated by Defendants to the direct detriment and damage of Plaintiff's own art clientele.

92. Plaintiff is informed and believes and based thereon alleges as follows: On or about October 17, 1982, after establishing ASI, CST and RTC, and obtaining control over all Scientology corporate bank accounts throughout the world, and using monies, trust and labor contributed by Plaintiff, and procured through the fraud of Defendants upon Plaintiff, Captain Miscavige held a meeting of approximately 400 franchise holders operating Scientology corporations in San Francisco, California at which he appeared dressed in a naval full-dress uniform, as did other of the Defendants. At said meeting, Captain Miscavige informed the various franchise holders of the fact that he and the RTC had taken over all Scientology organizations. Captain Miscavige stated as follows:

93. Captain Miscavige further stated that every franchise holder would be required to sign a new agreement with RTC and that if they did not do so, they would be "fined or thrown into [a Scientology] jail." Individuals who objected to the RTC and ASI take-over of the assets were literally locked into rooms and interrogated with a crude lie detector called an E-Meter and were either forced to sign the new agreements or removed from their positions and deprived of their business, property and possessions. For example, certain persons expressed disapproval and an unwillingness to take part in the conspiracy and they were summarily ordered to the RPF "Running Program" in, among other places, the State of California's high desert, for 120 days - all with the benefit and use of Plaintiff's monies and labor. This was a forced program which involved the victim running around an orange telephone pole in the middle of the desert. For example, former RTC "boss", Defendant Vicki Aznaran, has testified that she was forced to literally run from 7:00 a.m. until 9:30 p.m. daily and was confined under armed guard. Vicki Aznaran and other victims were allowed only 30 minutes for lunch and for dinner. She finally escaped down a riverbed. Similarly, former "senior management" Scientologist, Jesse Prince, escaped with the help of local Indians, after years of being imprisoned at this high security, "re-education" gulag, from which countless persons have literally disappeared (Exhibit "E").

94. In or about 1982, at a public event attended by Plaintiff at the Flag Land Base in Clearwater, Florida, Captain Miscavige proudly proclaimed that he was working with Scientology's attorneys, as "Mission Ops" (meaning he was in charge or "i/c"), on a program known as "Mission Corporate Category Sort-Out" (or "MCCS") to reorganize the entire corporate structure of the Scientology enterprise with the specific intention that any further litigation against Defendants by enemies of Scientology, would be certain to either fail, be overwhelmingly and prohibitively expensive and, even if successful, would thwart satisfaction of any judgment entered against the Scientology enterprise.

95. Plaintiff is informed and believes and based thereon alleges as follows: Between March 1982 and November 1982, Commodore Hubbard, Pat Broeker, Captain Miscavige, Spurlock and others through ASI illegally transferred over 30 million dollars of funds belonging to the Church of Scientology, and in part contributed by Plaintiff's monies, trust and labor, to bank accounts of ASI and Commodore Hubbard in Liechtenstein and Luxembourg. These funds were transferred based on overly false or exaggerated billings by ASI to the Church of Scientology and contrary to representations made to Plaintiff in publications such as "What do your donations buy?"

96. Plaintiff is informed and believes and based thereon alleges as follows: Between November 1982 and the present, the Church of Scientology has paid millions of dollars, in part comprised of Plaintiff's monies, trust and labor, in attorneys' fees to various lawyers, who were instructed to engage in criminal, fraudulent and unethical conduct (e.g. , Church of Scientology v. Commissioner of Internal Revenue, 86 U.S. Tax Ct. Rptr. 381 (1984); U.S. v. Katter, 840 F.2d 118 (1st Cir. 1988); Church of Scientology v. Wollersheim, 42 Cal.App.4th 628 (1996)), at the expense of Plaintiff's monetary, trust and labor contributions to Defendants, without the requisite authority of the officers and directors of the Church of Scientology corporations. These attorneys' fees, and investigator's fees have been used as a money-laundering scheme to pay covert operatives, private investigators, and other costs in connection with a scheme to harass, intimidate, coerce and destroy all opposition to the Defendants as set forth below.

97. Plaintiff is informed and believes and based thereon alleges as follows: Between January 1982 and the present, Captain Miscavige and ASI, and certain others of the allegedly conspiring

Defendants herein, have illegally expended the following sums for unlawful purposes.

98. Plaintiff is informed and believes and based thereon alleges as follows: Between 1972 and 1982, from funds unknowingly and/or unwittingly contributed to by Plaintiff's monies, trust and labor, Defendants conspired together to defraud the Church of Scientology of in excess of 100 million dollars. This conspiracy was accomplished by the following overt acts:

99. For many years, Scientology has been embroiled in litigation. One of its written policies is to use litigation to "overwhelm," "harass" and wear down perceived enemies and would-be commercial competitors . According to Scientology dogma and religious scripture, "the purpose of a lawsuit is to harass, not win on the merits." Another Scientology directive is to "always attack, never defend." Such litigation is intended to eliminate, harass and intimidate witnesses, and to obstruct justice, and is funded by illegally and fraudulently obtained funds from Plaintiff among others. Defendants' engage in this massive over-litigation and abuse of the legal system in violation of their express contrary representations to the IRS, and in breach of their fraudulent settlement with the IRS which has deprived the United States taxpayers of over one billion dollars in tax revenues otherwise due and payable by Defendants to the IRS in the year 1993(http:\www.lermanet2.com/cos/taxanalysts/secretagreement.txt).

100. As part of a pattern of racketeering activity, Scientology has fraudulently procured copyright registrations, trademarks and service marks. In some instances, abandoned and unenforceable trademarks or service marks were given the color of right, legitimacy and law by thousands of fraudulent or false submissions made by Scientology to the United States Patent and Trademark office. Scientology has additionally procured copyrights, fraudulently by the use of the mails, by submitting false statements to the United States Copyright office.

101. Beginning in or about 1983, and continuing through the present, Scientology has used those fraudulently procured trademark registrations, "trade secrets" and copyrights, constituting "misuse of copyright" to extort large sums of money from Plaintiff, and to establish a fraudulent religious monopoly, all under the guise and misrepresentation of those monies being a "fixed donation" to a legitimate, law abiding and peaceful religion co-existing with other religions, which Plaintiff later learned it is demonstrably not.

102. Defendants have used and continue to use the fraudulentally obtained copyrights to consolidate their position of power and to monopolize and eliminate any "religious"/new age/self-improvement course competition in interstate commerce. Defendants have used threats of violence against Plaintiff to extort money under the color of right and law conferred by alleged ownership of the copyrights, and claimed "trade secrets", which they claim should be tax free.

103. Revenue generated by Scientology's false representations is utilized to pay for the advertising of products, including books, which were published and distributed by Defendants ASI and BPI, conceded for-profit corporations, to Plaintiff.

104. Defendants have used and continue to use, and "misuse," the fraudulently-obtained copyrights in breach of their express representations to the Plaintiff that they were recruiting him into a peaceful, law-abiding, bona fide, legitimate religion in the traditional and usual understanding of the word and concept of religion. Defendants have also used threats of violence to extort money under the color of right conferred by alleged ownership of the copyrights, trade secrets and other intellectual property, all without the knowledge or consent of the Plaintiff to whom Defendants owed contractual and fiduciary duties to expend the product of his monies, trust, time and labor in accordance with the Defendants' express and implied representation to Plaintiff which Defendants thereby breached. On July 21, 1998, the Wall Street Journal (p. A11), in its editorial column ("Review & Outlook"), wrote that Scientology had caused a Federal judge to "turn copyright law on its head" by claiming that "you can criticize the texts of a public religion . . . but a secret religion is immune."

105. Revenue generated by Defendants' false representations, and material non-disclosures was utilized to pay for the advertising of products, including books, which were/are published and distributed by Defendant ASI and Bridge Publications, once conceded for-profit corporations, and now used to further the fraudulent conduct that Defendants directed at Plaintiff and the peoples of the United States generally.

106. Revenue generated by Scientology's pattern of racketeering, which is generally non-taxable income following the Clinton Administration's sudden 1993 reversal of the contrary position taken by all U.S. Administrations since 1954 and consistently upheld by the nation's highest courts, is also used to finance covert "intelligence officers" (such as Scott Mayer, Garry Scarff and Frank Oliver) investigators (such as Eugene Ingram, John Gaw, Barry Silver, and Hank Batterton, and lawyers such as Earl Cooley; Sherman Lenskie; Harold Heller; Elliot Abelson; William Drescher; Howard Wietzman; Jack Quinn; Arnold & Porter; Williams & Connally; David Chodos; Kendrick L. Moxon; Samuel D. Rosen and Barbara Reeves of Paul, Hast