------------------------------------------------------------------- F.A.C.T.Net, Inc. (Fight Against Coercive Tactics Network, Incorporated) a non-profit computer bulletin board and electronic library 601 16th St. #C-217 Golden, Colorado 80401 USA BBS 303 530-1942 FAX 303 530-2950 Office 303 473-0111 This document is part of an electronic lending library and preservational electronic archive. F.A.C.T.Net does not sell documents, it only lends them according to the terms of your library cardholder agreement with F.A.C.T.Net, Inc. ===================================================================== ,3PACE 3ELOw FOR F@G 31. 1 (;REENF- O'REILLY. AR.NEW & OFtOiLi-Z7 @ -. C.."-@0- 2 Loe MQCLZS. CALJFORNIA OM17 I (2131 462-1122 FILED 3 L2131.42-1350 4 AUG2 1982 Plainti!@@ 5 Attorneys for COUNTY CLERK 6 7 a SUPERIOR COURT OF THE STATE OF CAL:FORNIA 9 FOR THE COUNTY OF LOS ;LNGELES 10I LARRY WOLLERSHEIM, CASE NO. C 332827 12 Plaintiff, SECOND AMENDED COKPLAINT FOR DAMAGES 13 V. (FRAUD, OUTRAGEOUS CONDUC-@, 14 CHURCH OF SCIENTOLOGY OF NEGLIGENT INFLICTION OF CALIFORNIA, a corporation; EMOTIONAL SHOCX) is CHURCH OF SCIENTOLOGY OF 16 FLORIDA, a corporation; L. RON HUBBARD, an individual; CHURCH OF SCIENTOLOGY, a 17 corporation; DOES 1 through 200, inclusive, 18 Defendants. 19 20 COMES NOW Plaintiff, LARRY WOLI.ERSEE::M, and for cal-,se, 21 of action against Defendants, and each of t'.iem, co-laiis ane 22 alleges as follows: 23 GENE@ ALLER.AT:ICIIS '4 1. That the true n-s and/or capaci-l-i-es, whet.'Ie: 5 individual, corporate, associate or othe--wise al@ defendants ooES I through 200, inclusive, anci each Of then, are u,-ikiown t 7 plaint4@ff whc, tlierefore, sues said defendants by such .@ict4---4-ou names. Plainti.4f is informed and believes and upon suc @.7 -k-L tliat each the @e4lendants infat-nation and belie-4 alleges liouslv named here4-n as a COE is legally reslDcns4-ble, @-ntent4-on- 3 ai-ly, negligently and/or in some other act4-onable marner, -@or the events and happenings hereinafter referred to and proxz-mately thereby cause the injuries and damages to plaintiff as hereinafter 6 alleged. The plai-itiff will seek leave of court to amend this 7 Complaint to insert the true names and/or cacacit-'-es of suc fictit4-ously named defendants when the same have I:een ascertained. 9 2. Plaintiff is informed and believes and thereuzcn 10 alleges that at all times mentioned herein and material hereto, 11 defendants, and each of them, were the agents, servants, emplovt:,-:. 12 and/or joint venturers of their co-defendants and were, as such, E@o 13 acting within the course, scope and authority of said agency, 14 employment and/or venture and that each and every deferdant, as 15 aforesaid, when acting as a princimal, was r-iegli-,ent i-n the < 16 selection and hiring of each and every other defendant as an 17 agent, employee, and/or joint venturer. 19 3. That at all tines mentioned herein and material hereto, plaintiff, LMMY WOLLERSHEIM, was a resident of the Countv 20 of Los Angeles, State of California. 21 4. That at all times mentioned herein and -naterial@ 22 hereto, defendant, L. RON HUBBARD, an individual, was the .4ounder 23 of the defendant, CHURCH OF SCIENTOLOGY, a corporation, and/or the 14 various other entities and organizations included within and/or 25 connected to the defendant, CHURCH OF SCIE.NTOLOGY, a cor=oraticn, 26 in the United States and around the world, includ4-ng, bu4- ict 27 limited to, the de@lendant, CHURC.Q OF SC'-ENTOLOGY OF CAL-@FORN-@.@, a 28 ct@rporation, and defendant, CHTJRCH OF SCIENTOLCG'Y OF FLORIIDA, a -2- cc--poration, and was and is .he origilato-- of any pol@i-c4-es ar.,-4 procedures followed by the de-@endant, CHURCH OF qC--@-NTCLOGY, a 3 corporation, and the various other -@o@.s c-4 the de-4endant, CJURC*I 4 oF SCIENTOLOGY, a corporation, hereinabove descr@ed, 4ncluding, 5 but not l@ted to, the defendant, C.QURCH OF SCIENTOLOGY OF 6 CALIFORNIA, a corporation, and defendant, CHURCH OF SCIENTOLOGY OF 7 FLORIDA, a corporation. a 5. Plaintiff is informed and believes and thereupcr, 9 alleges that at all times mentioned herein and material hereto, 10 defendant, CHTJRCH OF SCIENTOLOGY OF CALIFORNIA, was and is a 11 religious organization and/or business organized and exist4-ng r 12 2 a under and by virtue of the laws of the State of Califor.'iia and/or @z,g ;- c i one or more states of the United States of Amer a, and that sa d 14 defendant was and is authorized to do and is doing business in the u 15 State of California and that sa,'-d deferdant has regularly ccr.- 7..0 i . z b 161 ducted business in the State of California. z 17 6. Plaintiff is informed and bel4@eves and thereupon 18 alleges, that at all times mentioned herein and material hereto, 19 defendant, CEVRCH OF SCIENTOLOGY, was and is a religious organiza- 20 tion and/or business organized and existing under and by virtue c@- 21 the laws of the State of California and/or one or more states of 22 the United states of America and that said defendant was and is 23 authorized to do and is doing business in the States of Califor-iia 24 and that said defendant has regularly conducted business in the 25 State of California. 26 7. Plaintifl-: is in@@ormed and believes and therel-,=cr. 27 alleges that at all t4-mes mentioned herein and material Iieretc, 28 defendant, CHURCH OF SCIENTOLOGY OF FLORIDA, was and 4.s a -3- religious organ4-,zati.rl arld/