1 Graham E. Berry, SBN# 128503 3384 McLaughlin Avenue 2 Los Angeles, CA 90066 Telephone: 310.745-3771 3 Facsimile: 310.745-3771 Email:
[email protected] 4 Attorney for Plaintiff, 5 Francois G. Choquette. 6 7 SUPERIOR COURT OF CALIFORNIA 8 COUNTY OF RIVERSIDE 9 CENTRAL DISTRICT 10 FRANCOIS G. CHOQUETTE, an ) Case No. RIC 538634 11 individual ) ) Assigned: Hon. Sharon J. Waters, Dept.10 12 Plaintiff, ) v. ) FIRST AMENDED 13 ) COMPLAINT FOR DAMAGES FOR: CHURCH OF SCIENTOLOGY ) 14 INTERNATIONAL, a California ) 1. Assault & Battery corporation; BUILDING MANAGEMENT ) 2. Assault & Battery, Excessive Force 15 SERVICES, a California corporation; ) 3. False Arrest & Imprisonment DAVID ALAN DUNIGAN, an individual; ) 4. Negligent Hiring, Supervision and 16 KENNETH R. SEYBOLD, an individual; ) MATTHEW JAMES BUTLER, an ) Retention 17 individual; SALVATORE MEO, and ) 5. Negligence, Nuisance & Occupier’s individual; and DOES 1 through 20, ) Liability 18 inclusive, ) 6. Abuse of Process ) 7. Malicious Prosecution 19 Defendants. ) 8. Violation of California Civil Code § ) 52.1 20 ) ) 9. Violation of California Constitution 21 ) Article 1, §§1, 2, 3, 4, 7 & 13 ) 22 ) UNLIMITED CIVIL CASE ) 23 ) DEMAND FOR JURY TRIAL ) 24 )_ ) Complaint filed: October 22, 2009 25 ) Trial Date: None ) Motion Cut-off: None 26 CMC: April 23, 2010 27 28 1 Plaintiff, FRANCOIS G. CHOQUETTE, on information and belief, makes the following 2 allegations to support his First Amended Complaint as of right: 3 SECULAR ACTION 4 1. This First Amended Complaint is not directed at any of Defendants' religious beliefs or 5 freedoms. It is only directed at Defendants' demonstrably secular policies, processes, practices 6 and conduct in connection with, at the very most, religiously motivated conduct which is subject 7 to regulation for the protection of society.