Graham E. Berry, SBN# 128503 33 84 McLaughlin Avenue Los Angeles, CA 90066 Telephone: 3 10.745-3771 Facsimile: 3 10.745-3771 Email:
[email protected] Attorney for Plaintiff, Francois G. Choquette. 1 SUPERIOR COURT OF CALIFORNIA COUNTY OF RIVERSIDE CENTRAL DISTRICT FRANCOIS G. CHOQUETTE, an Case No. RIC 538634 individual ) 1 Assigned: Hon. Sharon J. Waters, Dept.10 Plaintiff, ? Y v. FIRST AMENDED COMPLAINT FOR DAMAGES FOR: CHURCH OF SCIENTOLOGY ) INTERNATIONAL, a California 1. Assault & Battery corporation; BUILDING MANAGEMENT ) 2. Assault & Battery, Excessive Force SERVICES, a California corporation; ) 3. False Arrest & Imprisonment DAVID ALAN DUNIGAN, an individual; ) 4. Negligent Hiring, Supervision and KENNETH R SEYBOLD, an individual; ) Retention MATTHEW JAMES BUTLER, an 1 individual; SALVATORE MEO, and 5. Negligence, Nuisance & Occupier's individual; and DOES 1through 20, Liability inclusive, ) 6. Abuse of Process 1 7. Malicious Prosecution H Defendants. j 8. Violation of California Civil Code § 52.1 9. Violation of California Constitution Article 1, §§1,2,3,4,7 & 13 UNLIMITED CIVIL CASE 1 DEMAND FOR JURY TRIAL ) - Complaint filed: October 22,2009 Trial Date: None Motion Cut-off: None CMC: April 23,2010 Plaintiff, FRANCOIS G. CHOQUETTE, on information and belief, makes the following allegations to support his First Amended Complaint as of right: SECULAR ACTION 1. This First Amended Complaint is not directed at any of Defendants' religious beliefs or freedoms. It is or& directed at Defendants' demonstrably secular policies, processes, practices and conduct in connection with, at the very most, religiously motivated conduct which is subject to regulation for the protection of society.