The Brain Injury Association, Abuse and Failure to Report Abuse
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Anonorange First Amended Complaint
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. -
Scientology Motion to Strike
LOBB CLIFF & LESTER, LLP Mark S. Lester [SBN 1 199671 David Cantrell [SBN 2277881 1325 Spruce Street, Suite 300 Riverside, California 92507 Telephone: (95 1) 788-941 0 Facsimile: (951) 788-0766 MOXON & KOBRIN Kendrick L. Moxon [SBN 1282401 3055 Wilshire Boulevard, Suite 900 Los Angeles, California 9001 0 Telephone: (2 13) 487-4468 Facsimile: (21 3) 487-5385 Attorneys for Defendants, Church of Scientology International, Inc.; Building Management Services, Inc.; Daniel Alan Dunigan (erroneously sued and served as David Alan Dunigan); Kenneth R. Seybold; Matthew James Butler and Salvatore Meo SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF RIVERSIDE 11 FRANCOIS CHOQUETTE, ) Case No. RIC 538634 1 ) Assigned for All Purposes to the Plaintiff, ) Honorable Sharon J. Waters 1 ) DEFENDANTS' NOTICE OF MOTION VS. ) AND MOTION TO STRIKE PORTIONS ) OF PLAINTIFF'S FIRST AMENDED ) COMPLAINT CHURCH OF SCIENTOLOGY \ INTERNATIONAL, a California corporation; (Sewed concurrently with Demurrer, Motion BUILDING MANAGEMENT SERVICES, a ) to Strike and Request for Judicial Notice) California cornoration; DAVID ALAN \ 1 DUNIGAN, & individual; KENNETH R. ) DATE: SEYBOLD, an individual; MATTHEW JAMES TIME: BUTLER, an individual; SALVATORE MEO, ) an individual; and DOES 1 through 20, inclusive 1 ) II Defendants. I 1. NOTICE OF MOTION TO STRIKE TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on the day of , 2010, at 8:30 a.m. or as soon thereafter as the matter may be heard in Department 10, Defendants Church of Scientology International, Inc.; Building Management Services, Inc.; Daniel Alan Dunigan (erroneously sued and served as David Alan Dunigan); Kenneth R. Seybold; Matthew James Butler and Salvatore Meo will and hereby do move this court for a Motion to Strike Portions of Plaintiffs First Amended Complaint.This motion is made pursuant to Code of Civil Procedure fjfj 435 and 436 on the ground those cited provisions of the Complaint are irrelevant, false or improper matters inserted in the pleading. -
010293 Scientology
Interfaith Evangelism BELIEF Scientology BULLETIN Cults, Sects, and New Religious Movements Official Name: Church of Scientology International Founder: L. Ron Hubbard, in 1954 Current Leaders: David Miscavige, (b. 1960); Heber C. Jentzsch (b.1935) Headquarters: Los Angeles, Calif.; Clearwater, Fla. (Flag Land Base) Organizations Associated with Scientology: Applied Scholastics National Commission on Law Enforcement Association for Better Living and Education and Social Justice (ABLE) Religious Technology Center Citizens Commission on Human Rights Sterling Management Systems Concerned Businessmen’s Association of America The Way to Happiness Foundation The Hubbard Dianetics Foundation International World Institute of Scentology Enterprises (WISE) Narconon/Criminon Publishing Organizations: New Era Publications, International; Bridge Publications, Inc. Key Publications: Dianetics: The Modern Science of Mental Health (1950) and other books by L. Ron Hubbard; What is Scientology? (1978) compiled by staff of the Church of Scientology International; Freedom magazine This Belief Bulletin highlights basic concepts of In 1954, Hubbard incorporated the Church of Scientology and gives Biblical responses. Scientology to promote his ideas using a religious facade. His books and church spread worldwide, but Hubbard History became a recluse. He spent most of his last years aboard Lafayette Ronald Hubbard was born in Nebraska in his yacht being waited on hand-and-foot. He died inaus- 1911. He spent most of his childhood on his grandfa- piciously in 1986. ther’s Montana ranch while his parents served overseas in the U.S. Navy. Hubbard later stated that visits with par- Commonly Used Scientology Terms ents to Asia in the 1920s introduced him to eastern Analytical mind: The conscious, rational, and problem philosophies and religions. -
Church of Scientology
Church of Scientology By Kurt Van Gorden Founder: Lafayette Ronald Hubbard; a.k.a., L. Ron Hubbard (1911-1986) Current Leader: David Miscavige, Chairman of the Board for the Religious Technology Center. Founding Date: 1953 Official Publications: All of L. Ron Hubbard’s books, publications, and audio messages that were produced under the auspices of Dianetics and Scientology have been officially proclaimed as scripture in the Church of Scientology. Organization Structure: Scientology church members belong to the International Association of Scientologists. The Continental Liaison Offices oversee the local missions and churches, also referred to as Ideal Churches or Ideal Orgs (organizations). The supreme church corporation is the Church of Scientology International headquarters in Los Angeles, California. Scientology’s new spiritual headquarters is located in Clearwater, Florida. Known as the Flag Building, it also serves as a land base for the highest staff positions, the maritime Sea Org, whose members wear naval-style uniforms with officer ranks. Other Organizational Names: Scientology Celebrity Centers, Citizens Commission on Human Rights, Association for Better Living and Education—ABLE, Applied Scholastics, Bridge Publications, Criminon, Narconon, Foundation for Religious Tolerance, Sterling Management, Worldwide Institute of Scientology Enterprises—WISE, and The Way to Happiness Campaign. Unique Terms: Dianetics (through the mind or soul), Scientology (knowing how to know), Thetan, Engram, Auditing, Clear, E-Meter, and Operating Thetan (OT). HISTORY L. Ron Hubbard was a successful science fiction writer who published over 15,000,000 words between 1932 and 1950 under 20 pen names. Some critics believe that Hubbard may have predicted his forthcoming church. While speaking at a 1949 New Jersey science fiction convention, Hubbard reportedly stated, “Writing for a penny a word is ridiculous. -
Scientology: CRIMINAL TIME TRACK ISSUE I by Mike Mcclaughry 1999
Scientology: CRIMINAL TIME TRACK ISSUE I by Mike McClaughry 1999 The following is a Time Track that I put together for myself and some friends at the time, in 1999. I originally used the pseudonym “Theta” at the request of Greg Barnes until he was ready to “go public” with his defection from Scientology. I also used the pseudonym “Theta 8-8008” around this same time period. Bernd Luebeck, Ex-Guardian’s Office Intelligence and then Ron’s Org staff ran the website www.freezone.org. In 1999, just after my time track was released privately, Bernd used it on his website as-is. He later expanded on my original time track with items of interest to himself. Prior to my doing this time track, Bernd, (nor anyone else involved with Scientology on the internet), had ever thought of the idea to do things this way in relation to Scientology. Mike McClaughry BEGIN An open letter to all Scientologists: Greetings and by way of introduction, I am a Class 8, OT 8, who has been in the Church for many decades and I am in good standing with the Church. I am a lover of LRH’s technology and that is my motivation in writing you and in doing what I am now doing. It came to my attention, sometime in the not too distant past, that the current top management of the Church, particularly David Miscavige, is off source. One of the ways he is off-source is that he has made the same mistake as the old Guardian’s Office staff made, engaging in criminal activities to solve problems. -
True Nyms and Crypto Anarchy
True Nyms and Crypto Anarchy Timothy C. May One of the biggest issues in cyberspace these days, one that will continue to be an issue as long as there is such a venue as the Internet, is the safety of communication from prying eyes. In the detailed and persuasive essay that follows, Tim May, formerly a physicist at Intel and one of the founding members of the Cypherpunks, discusses the big issues involved—invasion of privacy, the specter of government interference in personal affairs, the use of electronically forwarded information by a variety of people, entities, and organizations for purposes other than those intended by the forwarder … these are all issues of tremendous importance to anyone who uses the Internet —and that means just about everyone, in one way or another. In a previous age, these issues were not of such great importance, for there was never the possibility that anyone could find and gather enough information to do harm to others in the ways that are now possible with the Internet. Today, however … Read Tim May’s essay and you’ll never feel quite as safe as you did a moment before you read these pages. This article was written in 1996. 25 The Impact of True Names “True Names” came to my attention in 1986, when a friend of mine gave me a dog-eared Xerox copy and said “You need to read this.” But before I even started reading this samizdat edition, the Bluejay Books trade paperback edition appeared and that’s what I read, saving my eyesight and giving Vernor Vinge his proper cut of the action. -
Zerohack Zer0pwn Youranonnews Yevgeniy Anikin Yes Men
Zerohack Zer0Pwn YourAnonNews Yevgeniy Anikin Yes Men YamaTough Xtreme x-Leader xenu xen0nymous www.oem.com.mx www.nytimes.com/pages/world/asia/index.html www.informador.com.mx www.futuregov.asia www.cronica.com.mx www.asiapacificsecuritymagazine.com Worm Wolfy Withdrawal* WillyFoReal Wikileaks IRC 88.80.16.13/9999 IRC Channel WikiLeaks WiiSpellWhy whitekidney Wells Fargo weed WallRoad w0rmware Vulnerability Vladislav Khorokhorin Visa Inc. Virus Virgin Islands "Viewpointe Archive Services, LLC" Versability Verizon Venezuela Vegas Vatican City USB US Trust US Bankcorp Uruguay Uran0n unusedcrayon United Kingdom UnicormCr3w unfittoprint unelected.org UndisclosedAnon Ukraine UGNazi ua_musti_1905 U.S. Bankcorp TYLER Turkey trosec113 Trojan Horse Trojan Trivette TriCk Tribalzer0 Transnistria transaction Traitor traffic court Tradecraft Trade Secrets "Total System Services, Inc." Topiary Top Secret Tom Stracener TibitXimer Thumb Drive Thomson Reuters TheWikiBoat thepeoplescause the_infecti0n The Unknowns The UnderTaker The Syrian electronic army The Jokerhack Thailand ThaCosmo th3j35t3r testeux1 TEST Telecomix TehWongZ Teddy Bigglesworth TeaMp0isoN TeamHav0k Team Ghost Shell Team Digi7al tdl4 taxes TARP tango down Tampa Tammy Shapiro Taiwan Tabu T0x1c t0wN T.A.R.P. Syrian Electronic Army syndiv Symantec Corporation Switzerland Swingers Club SWIFT Sweden Swan SwaggSec Swagg Security "SunGard Data Systems, Inc." Stuxnet Stringer Streamroller Stole* Sterlok SteelAnne st0rm SQLi Spyware Spying Spydevilz Spy Camera Sposed Spook Spoofing Splendide -
Benefits I Have Received from Scientology Auditing and Train
14 August 1997 Dear I have been asked to describe certain 'secular' benefits I have received from Scientology auditing and training that are not generally understood to be religious or spiritual in nature and how these have affected my community services activities. From my own schooldays I had a purpose to help other children gain a good education and to this end became a qualified teacher and pursued this profession until I married and had a family. I then came into contact with Scientology and through it gained greater self reliance and greater confidence in handling projects Also I was trained in the use of the study method developed by L Ron Hubbard and decided that I wanted to use it to help children to study better in school. With the help of a local West Indian businessman and other volunteers I started Riving supplementary teaching in the evening to disadvantaged children in Brixton , something which was especially wanted by West Indian parents in the drea. This project which we named B.E.S.T, ( the Basic Education and Supplementary Teaching .Association ) is now an authorised charity and continues to provide supplementary teaching and vacation projects in the Brixton area. More recently I have taken on another volunteer activity, that of bringing this study method to teachers in a country in Southern Africa. The education authorities in that country had become aware that the academic results being achieved in their schools were not sufficiently being translated into success in the professions and the workplace. L Ron Hubbard's Study Technology with its emphasis on fully understanding and being able to apply the data being studied was demonstrated in a pilot project and was shown to markedly increase student interest and comprehension and to greatly reduce truancy and its introduction was approved. -
Dear Matt, While I Understand Your Predicament, I Fully Understand The
Dear Matt, While I understand your predicament, I fully understand the situation you and your ASA colleagues find yourselves in. It is not often one has to deal with an organisation as deceptive as The Way To Happiness Foundation. To cut to the chase - while the ASA acknowledges the connection between The Way To Happiness Foundation and Scientology, the ASA believes that The Way To Happiness Foundation is a separate charity in its own right. I intend to present evidence establishing the following four points: 1) The Way To Happiness Foundation is under control of Scientology international management. 2) The Way To Happiness Foundation is run by Scientologists. 3) The Way To Happiness Foundation is being run for the purpose of Scientology. 4) A proportion of donations collected by The Way To Happiness Foundation go to Scientology. If the above four points are true, then the claim that The Way To Happiness Foundation is a separate charity in its own right must be rejected, and future advertisements on behalf of this group must clearly reflect this. 1. The IRS application and decision. I will begin by revisiting the IRS position. The 1023 IRS filing made in 1993 as part of The Way To Happiness Foundation’s application for tax-exemption is available from http://www.xenu-directory.net/documents/corporate/irs/1993-1023-twth.pdf . From page 10 that 1023 filing: Evidence piece 1 From page 9 of that same document: Evidence piece 2 Evidence piece 3 From the 1993 IRS closing agreement that gave The Way To Happiness Foundation and other Scientology entities their tax-exemption, Scientology-related entities qualifying for tax-exemption are defined thus (http://www.cs.cmu.edu/~dst/Cowen/essays/agreemnt.html#Scientology- related%20entity ): “4. -
The Histories and Origins of Memetics
Betwixt the Popular and Academic: The Histories and Origins of Memetics Brent K. Jesiek Thesis submitted to the Faculty of Virginia Polytechnic Institute and State University in partial fulfillment of the requirements for the degree of Masters of Science in Science and Technology Studies Gary L. Downey (Chair) Megan Boler Barbara Reeves May 20, 2003 Blacksburg, Virginia Keywords: discipline formation, history, meme, memetics, origin stories, popularization Copyright 2003, Brent K. Jesiek Betwixt the Popular and Academic: The Histories and Origins of Memetics Brent K. Jesiek Abstract In this thesis I develop a contemporary history of memetics, or the field dedicated to the study of memes. Those working in the realm of meme theory have been generally concerned with developing either evolutionary or epidemiological approaches to the study of human culture, with memes viewed as discrete units of cultural transmission. At the center of my account is the argument that memetics has been characterized by an atypical pattern of growth, with the meme concept only moving toward greater academic legitimacy after significant development and diffusion in the popular realm. As revealed by my analysis, the history of memetics upends conventional understandings of discipline formation and the popularization of scientific ideas, making it a novel and informative case study in the realm of science and technology studies. Furthermore, this project underscores how the development of fields and disciplines is thoroughly intertwined with a larger social, cultural, and historical milieu. Acknowledgments I would like to take this opportunity to thank my family, friends, and colleagues for their invaluable encouragement and assistance as I worked on this project. -
Comparison Between Freedom of Religion in Germany and in the United States in General and the Treatment of the Church of Scientology Specifically
University of Georgia School of Law Digital Commons @ Georgia Law LLM Theses and Essays Student Works and Organizations 2000 COMPARISON BETWEEN FREEDOM OF RELIGION IN GERMANY AND IN THE UNITED STATES IN GENERAL AND THE TREATMENT OF THE CHURCH OF SCIENTOLOGY SPECIFICALLY WOLFGANG EICHELE University of Georgia School of Law Follow this and additional works at: https://digitalcommons.law.uga.edu/stu_llm Part of the Civil Rights and Discrimination Commons, Comparative and Foreign Law Commons, First Amendment Commons, Human Rights Law Commons, and the Religion Law Commons Repository Citation EICHELE, WOLFGANG, "COMPARISON BETWEEN FREEDOM OF RELIGION IN GERMANY AND IN THE UNITED STATES IN GENERAL AND THE TREATMENT OF THE CHURCH OF SCIENTOLOGY SPECIFICALLY" (2000). LLM Theses and Essays. 284. https://digitalcommons.law.uga.edu/stu_llm/284 This Dissertation is brought to you for free and open access by the Student Works and Organizations at Digital Commons @ Georgia Law. It has been accepted for inclusion in LLM Theses and Essays by an authorized administrator of Digital Commons @ Georgia Law. Please share how you have benefited from this access For more information, please contact [email protected]. COMPARISON BEMI^Filii i^:;l^ IN ; GERiAIW AND IN THE UNITED sIteSS:^ IN GEERAL ;; AND THE TREATIVInT i^' Tft I ^ • : CHURCH OF SCENTOL OG Y SPEGFICALIY :ang Eichele The University of Georgia Alexander Campbell King Law Library UNIVERSITY OF GEORGIA LAW LIBRARY 3 8425 00347 5154 Digitized by tine Internet Arciiive in 2013 http://arcliive.org/details/comparisonbetweeOOeicli COMPARISON BETWEEN FREEDOM OF RELIGION IN GERMANY AND IN THE UNITED STATES IN GENERAL AND 1 HE TREATMENT OF THE CHURCH OF SCIENTOLOGY SPECIFICALLY by WOLFGANG EICHELE 1. -
L. Ron Hubbard Common-Sense Moral Code Is the Failures of Psychiatry 36 Achieving Remarkable Success in Schools
Volume 31, Issue 2 $2.50 Investigative reporting in the public interest Published by the Church of Scientology since 1968 The Hidden Hand of Violence Recent investigations shed new light on causes of violence in society. Also in this issue: Bringing Back Morals with The Way to Happiness From the Editor’s Desk has been eroded through the last four decades of “progressive education” — a system designed more for psychological conditioning than academic success. The Add the wholesale labeling of children with psychiatric “disorders” (such as “Attention Deficit Hyperactivity Disorder” and a host of “Learning Disorders”) for exhibiting much of what was previously considered normal childhood behavior. Erosion These labels not only excuse the educa- tional shortcomings of our schools, but the youth who receive them are told that they are responsible neither for what they do nor for the decisions they make. In fact, and of Right perhaps not so coincidentally, the Denver Post reported in December 1996 that federal law prohibited the expulsion of three kids who passed a gun around at school because they were classified as and “special-education” students. These stu- dents were not considered responsible for what they did. Finally, add a chemical catalyst of mind- altering psychiatric drugs and the result is volatile and even deadly. Keep in mind, too, Wrong that the types of “special education” students who are not held responsible for nalert Feeding Christians to lions was once popu- passing around deadly weapons at school columnist lar “sport.” For centuries, public executions are the ones most likely to be on such drugs.