Burchett v. Narconon: Complaint

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Ryan A. Hamilton
CA BAR NO. 291349
HAMILTON LAW
5125 S. Durango Dr., Ste. C
Las Vegas, NV 89113
(702) 818-1818
(702) 974-1139 (fax)
[email protected]

Attorney for the plaintiffs,
Claudia and Sarah Burchett

UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF CALIFORNIA

CLAUDIA BURCHETT, an Ohio Citizen; and
SARAH BURCHETT, an Ohio Citizen,

Plaintiffs,

vs.

NARCONON FRESH START d/b/a
SUNSHINE SUMMIT LODGE;
ASSOCIATION FOR BETTER LIVING AND
EDUCATION INTERNATIONAL;
NARCONON INTERNATIONAL and DOES 1-
100, ROE Corporations I – X, inclusive,

Defendants.



Case No.



COMPLAINT AND JURY DEMAND


Plaintiffs Claudia Burchett and Sarah Burchett (“Plaintiffs”), by and through counsel, Ryan
Hamilton of Hamilton Law, LLC, allege the following:
I.
PARTIES
1. Plaintiffs Claudia Burchett and Sarah Burchett are residents of and for the purposes of
determining federal diversity jurisdiction citizens of Ohio.
'14CV1678 RBB BEN
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2. Defendant Narconon Fresh Start (hereafter “Fresh Start”), is, and at all times relevant to
this Complaint was, a corporation incorporated under the laws of, and with its principal place of
business in, the State of California. Defendant has been at all relevant times transacting business in
Warner Springs, San Diego County, California. Fresh Start may be served with process through its
registered agent, Mark Kirwin, 4480 Market St., Ste. 804, Ventura, CA 93003.
3. Defendant Narconon International is a California corporation with its headquarters in Los
Angeles, California.
4. As set forth in more detail below, Narconon International exercises control over the time,
manner, and method of Fresh Start’s operations.
5. Narconon International was doing business in the State of Nevada by and through its agent
and subsidiary/licensee Defendant Narconon Fresh Start. Narconon International may be served
with process through its registered agent, Sherman D. Lenske, 6400 Canoga Ave., Suite 315,
Woodland Hills, CA 91367.
6. Fresh Start and Narconon International are subsidiaries of the Association for Better
Living and Education (“ABLE”). ABLE oversees the drug rehabilitation, education, and criminal
justice activities of the Church of Scientology including, but not limited to, Fresh Start and
Narconon International.
7. Defendant ABLE is a corporation registered in the State of California with its headquarters
in Los Angeles, California.
8. ABLE controls the time, manner, and method of Narconon International’s and Fresh
Start’s businesses by actively managing their daily operations, including conducting inspections of
Narconon centers and creating, licensing, and approving their marketing materials.
9. ABLE transacts business in the State of California by and through its agents, Narconon
International and Narconon Fresh Start. ABLE may be served with process through its registered
agent, Sherman D. Lenske, 6400 Canoga Ave., Suite 315, Woodland Hills, CA 91367.
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10. Plaintiff is unaware of the true names and capacities, whether individual, corporate,
associate, or otherwise, of Defendant DOES 1-100, inclusive, and, therefore, sues these
Defendants by fictitious names. Plaintiff will seek leave of this Court to amend this Complaint
when the identities of these Defendants are ascertained.
II.
JURISDICTION AND VENUE
11. This Court has subject jurisdiction pursuant to 28 U.S.C. § 1332. The amount in
controversy exceeds $75,000.00, and there is complete diversity between the parties.
12. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(a) because a substantial portion
of the events and omissions giving rise to this lawsuit occurred in this District, and the Court has
personal jurisdiction over each of the parties as alleged throughout this Complaint.
III.
FACTUAL ALLEGATIONS
13. On or about December 7, 2012, Claudia was searching the Internet for a drug rehabilitation
facility for her daughter, Sarah. Claudia found a website called “drugrehabs.org” or words to that
effect. This website purported to provide help in finding an appropriate drug and alcohol
rehabilitation facility.
14. Claudia called an “800” number listed on the website, 1-855-378-4734. She spoke with a
representative named “Ryan.” Ryan indicated that he was a drug and alcohol counselor and
wanted to get information from Claudia so he could recommend the most appropriate rehab
facility.
15. After listening to Claudia explain her daughter’s situation, Ryan told Claudia that her
daughter had a Category 3 drug addiction. Further, Ryan told Claudia that her daughter needed a
long-term comprehensive program lasting at least 90 days. Ryan explained that the treatment
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would need to be at least 90 days because it takes at least that long for an addict’s central nervous
system to return to normal.
16. Ryan explained that during that 90-day period an addict’s brain is in “frantic mode” as the
addict’s brain is seeking drugs or alcohol. To describe an addict’s brain during this time, Ryan
used the example of someone running late for an appointment and not being able to find her keys.
17. Ryan then explained to Claudia what types of treatment would not work for her daughter
and that she should avoid. Ryan warned Claudia to avoid “state or government funded” rehab
programs because these programs were for “hardened criminals” and had only a “1 – 3 % success
rate.” Ryan explained that these programs fail because you “can’t punish the addiction out” of an
addict.
18. Ryan next explained to Claudia which rehab would work. These programs included
“Passages Malibu,” “Betty Ford,” and “Promises.” Ryan explained that these programs were
successful because they used cognitive behavioral and individual therapy. However, Ryan
explained that these programs were extremely expensive.
19. Finally, Ryan explained the last category of rehab programs – non-profit programs that are
a minimum of 90 days. Ryan explained that Narconon Fresh Start was one of these programs.
Ryan represented that Fresh Start charged a flat fee between $30,000 and $35,000 and had a 76%
success rate. Further, Ryan represented that some of the Fresh Start programs had a written
guarantee.
20. Ryan then explained that he believed that the Narconon Fresh Start program was the best
fit for Claudia’s daughter. Ryan then had Claudia go the website www.drugrehab.com. This
website “reroutes” the user to www.freshstart.net. This is a website for Narconon Fresh Start.
21. Ryan then indicated that he would attempt to reach a Narconon Fresh Start counselor who
could speak with Claudia. After a few moments, Ryan came back on the line and told Claudia he
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had Narconon Fresh Start counselor Dan Carmichael on the other line and that Carmichael was
ready to talk to Claudia. Ryan then transferred Claudia to Dan Carmichael.
22. Carmichael then represented to Claudia that Narconon Fresh Start offered “individualized
cognitive therapy” and had a sauna program that was capable of flushing residual drug toxins out
of Sarah’s fatty tissue and could thereby reduce or eliminate her drug cravings.
23. Based on the representations of Carmichael and Ryan, and on the information she had read
on www.freshstart.net, Claudia agreed to admit Sarah into the Narconon Fresh Start program.
24. Claudia paid $34,000 for the program.
25. The representative “Ryan” on the phone used a script known as the “DRO Script.” The
DRO Script is attached hereto as Exhibit A. The DRO Script is an internal Narconon document
that Narconon makes available to its salespersons.
26. Although Ryan held himself out to Claudia to be an independent representative capable of
referring her to any number of treatment facilities, Ryan was using a Narconon script designed to
refer callers to Narconon only.
27. Claudia’s handwritten notes from her call with Ryan and Dan Carmichael are attached
hereto as Exhibit B. Claudia’s notes from her call with Ryan show that Ryan stuck closely to the
script when speaking with Claudia.
28. The DRO Script also indicates that the calls are recorded. Exhibit A, at p. 8. At no point
during the call did Claudia give Ryan or Dan Carmichael permission to record their conversation
which included very private details about Plaintiffs.
29. Sarah flew to California and after completing medical detox, she began the program at
Fresh Start at their Sunshine Summit Lodge facility near Warner Springs, California.
30. Fresh Start uses the the Narconon “Treatment” Program. This program consists of two
components: (1) course materials consisting of eight books by L. Ron Hubbard; and (2) a sauna
and vitamin program known as the “New Life Detoxification Program.”
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31. Despite Dan Carmichael’s representation that Fresh Start provided “individualized
cognitive therapy,” each patient in the Narconon program receives exactly the same written
materials.
32. Fresh Start, on its website and in the contract presented to Claudia, represents that its
treatment program is “secular” and that religion is not a part of the program. This is false. As a
former Executive Director of a Narconon center attests, the Narconon program consists entirely of
Scientology. Attached hereto as Exhibit C is the Affidavit of Eric Tenorio.
33. The written materials that Fresh Start had Sarah study as “treatment” consisted entirely of
Scientology doctrine and rituals. These rituals are not even related to the treatment of substance
abuse.
34. In addition, Fresh Start had Sarah participate in its sauna program known as the “New Life
Detoxification.” The New Life Detoxification program is identical to the Scientology ritual known
as the “Purification Rundown,” or the “Purif.” The Purification Rundown is a required component
of Scientology training and is part of Scientology’s “Bridge to Total Freedom.”
35. Fresh Start’s rationale for the sauna program is that residue of many different types of drug
remain the body’s fatty tissue long after use. The drug residue is released from the fatty tissue
from time-to-time into the bloodstream causing the individual to crave the drug, and, ultimately,
relapse. Fresh Start claims that the sauna program flushes these residual drug toxins out of the
addict’s system thereby reducing the cravings the residue causes.
36. Under the New Life Detoxification program, students first exercise vigorously before
entering the sauna each day. On entering the sauna, Narconon requires each student to ingest
increasing doses of Niacin and a “vitamin bomb.” Fresh Start increased Sarah’s dosages of Niacin
well beyond the recommended daily allowance.
37. Fresh Start requires students to spend six hours per day for five weeks in a sauna at
temperatures between 160 and 180 degrees Fahrenheit.
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38. There were no medical personnel overseeing Sarah while she was undergoing the sauna
program.
39. Fresh Start’s claims about the benefits of its sauna program, i.e., Scientology’s Purification
Rundown, are false and do not withstand scientific scrutiny.
40. In a prior lawsuit, Dr. Louis A. Casal, an expert retained by Narconon International and
Narconon of Northern Georgia in a wrongful death suit filed against those entities, testified at a
deposition. Relevant portions of Dr. Casal’s deposition testimony are attached hereto as Exhibit
D. When asked under oath about the New Life Detoxification Program, he testified that there is no
scientific basis for the notion that sweating in a sauna detoxifies a person’s body or treats
addiction:
Q. Have you looked at the Narconon literature on what Narconon contends the
benefits from the sauna are?
A. [Dr. Casal] Yes, I have.
Q. And the sauna program, what Narconon contends is that in – it in fact detoxifies
your body. True?
A. True.
Q. But there’s no scientific basis that you can point to to support that contention, is
there, sir?
A. You’re correct.
Q. So when Narconon states that the sauna program detoxifies its students, you’re not
aware, as a medical doctor, of any scientific basis for that contention?
A. I agree.
Exhibit D, Deposition of Dr. Louis Casal, 136:21 – 137:9.
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41. Narconon claims a success rate of 76% for all Narconon centers, including Narconon
Fresh Start d/b/a Sunshine Summit Lodge. Narconon has published no studies or other verifiable
evidence to support their claimed success rates.
42. Dr. Casal, the medical expert retained by Narconon International in another lawsuit,
testified at his deposition that he was not convinced Narconon’s claimed success rate was true:
Q. Okay. What are you relying on – well, let me ask you this; do you believe that 76
percent success ratio is accurate?
A. [Dr. Casal]. Mr. Harris, I’ll be honest with you, that’s a big number.
Q. Yeah, it’s – it’s a real big number.
A. It’s a big number.
Q. And it’s completely inconsistent –
A. I – I hope it’s true, but, I mean, I would need some convincing.

Q. Okay. Do you have any idea where Narconon is getting the numbers that it’s using?
A. You know, in the interest of time – I just didn’t have enough time to delve deeper
into those studies, Mr. Harris. And I – I would be happy to, but, no, I don’t have a clear
understanding of where that 70 – 70-something number came from, no, sir.
Exhibit D, Deposition of Dr. Louis Casal, 124:21 – 125:5; 126:1 – 7.
43. In addition, the Director of Legal Affairs for Narconon International, Claudia Arcabascio
advised the Narconon Freedom Center not to say they have a 70% success rate when responding to
a Better Business Bureau complaint. Arcabascio advised against citing the success rate because
“we do not have scientific evidence of it.” Attached hereto as Exhibit E is a copy of Ms.
Arcabascio’s e-mail to the Narconon Freedom Center.
44. Narconon is well aware that there is no support for Narconon’s claimed success rate, but
nonetheless advertised a 76% success rate to Claudia despite that awareness.
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45. During Sarah time at Fresh Start, the facility was staffed with recent patients or
“graduates” from the Narconon program.
46. Narconon documents indicate that the Narconon program is used to recruit patients into the
Church of Scientology. For example, a Narconon document titled the “Narconon Technical Line-
Up” provides a flow chart of a patient’s experience into and through the Narconon program. The
document shows that when a patient finishes the Narconon program, the patient is to be “route[d]
to the nearest Org for further services if the individual so desires.” “Org” is Scientology jargon for
an individual church providing services for the Church of Scientology. A copy of the “Narconon
Technical Line-Up” is attached hereto as Exhibit F.
47. Narconon and the Church of Scientology consider the Narconon program to be the “Bridge
to the Bridge.” That is, Narconon considers its program to be an initial step into getting on
Scientology’s “Bridge to Total Freedom,” the key spiritual journey that practitioners of the
Scientology religion undertake. See, e.g., “Narconon News, 1974, Volume 6, Issue 3: Narconon Is
The Bridge to The Bridge,” attached hereto as Exhibit G.
48. Because of the strange “treatments” she was being subjected to at Fresh Start, Sarah
became increasingly distressed and paranoid. She had great difficulty sleeping and eating and lost
approximately thirty pounds. Sarah barely spoke.
49. Sarah was the valedictorian of her high school class. When she left for Narconon she was
tremendously capable, albeit struggling with addiction. During her stay at Narconon, she had
difficultly following through on simple tasks.
50. In February of 2013, Claudia came to see Sarah at Fresh Start. She barely recognized her
daughter. Claudia removed Sarah from Fresh Start.
51. On leaving Fresh Start, Sarah had to be hospitalized for psychiatric problems she incurred
as a result of the bizarre “treatments” she was subjected to at Narconon.

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Narconon International and ABLE Control Narconon Fresh Start
52. Plaintiff incorporates by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further alleges as follows:
53. Narconon International publishes manuals that individual Narconon Centers such as Fresh
Start d/b/a Sunshine Summit Lodge are required to follow in operating the individual Narconon
center. Two of these manuals are entitled “Opening A Successful Narconon Center” and “Running
An Effective Narconon Center.”
54. These manuals indicate that an individual Narconon center can do very little without the
approval of Narconon International and ABLE.
55. Narconon Fresh Start d/b/a cannot transfer, demote, or dismiss a permanent staff member
without the approval of Narconon International.
56. Narconon International has ultimate authority over the hiring of any Fresh Start staff
member.
57. Narconon International serves as a Human Resources department for individual Narconon
centers by handling disputes between staff members at Fresh Start d/b/a Sunshine Summit Lodge.
58. Narconon International and ABLE must approve Fresh Start’s websites before they can ‘go
live” on the Internet or before they are changed.
59. Narconon International and ABLE monitor the delivery of the “treatment” that Fresh Start
provides. The written materials in the Narconon program consist of the writings and works of L.
Ron Hubbard. Narconon and Scientology refer to these materials as “technology” or “tech.”
60. A fundamental premise of the Narconon program is that tech must be delivered and applied
exactly as it is written. To that end, Narconon International and ABLE monitor and conduct
inspections to ensure that staff members at Fresh Start d/b/a Sunshine Summit Lodge are
delivering the tech contained in the Narconon written materials exactly as they should be.
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Narconon International and ABLE micromanage and instruct Fresh Start staff as to how they
should perform their jobs.
61. Narconon International receives ten percent of Fresh Start d/b/a/ Sunshine Summit Lodge’s
gross income.
62. Fresh Start is required to receive approval from Narconon International for all promotional
materials it sends out for the facility. Narconon International also assists Fresh Start with its
marketing and markets Sunshine Summit Lodge on Narconon International’s website.
63. Narconon International requires that each individual Narconon center send it weekly
reports of the center’s statistics.
64. As set forth above, Narconon International advises individual Narconon centers on legal
issues, including requests for refunds and Better Business Bureau complaints.
65. Narconon International and ABLE dictate the content of promotional materials for
individual centers, including the false claims individual Narconon centers make such as (a) that
the Narconon program has a 76% success rate, and (b) that the Narconon sauna program can
reduce or eliminate drug cravings.
66. Narconon International also handles public relations for individual Narconon centers and,
in particular, works to combat any negative publicity a center receives.
FIRST CLAIM FOR RELIEF
UNJUST ENRICHMENT
67. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation
set forth in the preceding paragraphs and further allege as follows:
68. Defendants received benefits from Plaintiffs, including without limitation, $34,000.00 for
drug rehabilitation services that Defendants promised to provide.
69. Defendants did not provide, nor were they equipped to provide, Plaintiff Sarah Burchett,
any of the drug rehabilitation services they promised to provide.
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70. Under the circumstances, it would be unjust to allow the Defendants to retain the benefits
they obtained from Plaintiffs.
SECOND CLAIM FOR RELIEF
FRAUD
71. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further alleges as follows:
72. The following is a non-exhaustive list of false representations Defendants knowingly
made to the Plaintiffs: (i) that the Narconon Fresh Start program has a 76% success rate; (ii) that
the Narconon program is secular and does not involve the study or practice of any religion; (iii)
that Sarah would receive “individualized cognitive therapy” at Narconon Fresh Start; (iv) that
Narconon’s sauna program, i.e, the Purification Rundown, is safe and has been scientifically
proven as effective at reducing or eliminating an addict’s drug cravings; and (v) that “Ryan” was
independent of and not affiliated with Narconon Fresh Start and was capable of referring Plaintiffs
to any number of drug treatment programs.
73. Dan Carmichael, a Fresh Start employee, made these statements to Claudia on or about
December 7, 2012, to induce Claudia to admit her daughter to Narconon. Narconon also made
these statements on their websites, www.drugrehab.org, www.drugrehab.com, and
www.freshstart.net. “Ryan” also made these statements on or about December 7, 2012, to Claudia
when he was pretending to be an independent representative from www.drugrehabs.org.
74. Narconon International and ABLE, by the express terms of their training manuals, approve
Narconon Fresh Start’s websites and promotional materials. Narconon International and ABLE
control the time, manner, and place of Narconon Fresh Start’s promotional activities and also
profit from them.
75. Narconon International and ABLE supervise the day-to-day activities of Narconon Fresh
Start d/b/a Sunshine Summit Lodge. Narconon International and ABLE also produce the false
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claims about the success rate of the Narconon program, the secular nature of the program, and the
ability of its sauna program to reduce or eliminate an addict’s drug cravings by sweating out
toxins in a sauna.
76. As a proximate result of Defendants’ fraudulent conduct, Plaintiffs have suffered pecuniary
damages as well as physical injuries and mental anguish requiring hospitalization.
THIRD CLAIM FOR RELIEF
NEGLIGENCE
77. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
78. Defendants owed Plaintiff Sarah Burchett a duty to render substance abuse treatment to her
in a manner that did not subject her to an unreasonable risk of harm. Defendants further had a duty
of care to render reasonably safe and effective treatment to her.
79. Defendants breached these duties by providing Sarah Burchett Scientology doctrine and
rituals in lieu of actual substance abuse treatment. Defendants further breached their duties to
Sarah Burchett by failing to staff Fresh Start with duly qualified personnel. Instead, Defendants
staffed Fresh Start with persons whose sole or primary qualification was that they had “graduated”
from the Narconon program.
80. As provided in Narconon International’s manuals, Narconon International has ultimate
authority over staffing at individual Narconon centers. In addition, Narconon International trains
staff to deliver the Narconon “treatment” program.
81. Narconon International disseminates the Narconon program. Narconon International
knows or should know that the Narconon program consists entirely of Scientology practices and
teachings that are not even related to substance abuse treatment.
82. As a proximate result of Defendants’ breaches of the above duties, Plaintiffs have suffered
mental anguish, including intense paranoia, and pecuniary injuries in excess of $75,000.00.
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FOURTH CLAIM FOR RELIEF
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
83. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further alleges as follows:
84. Defendants engaged in extreme and outrageous conduct with the intention of causing, or
with reckless disregard of the probability of causing Plaintiff Sarah Burchett severe or extreme
emotional distress. Defendants’ extreme and outrageous conduct consisted of creating a website
that provided the appearance of a drug rehabilitation referral service and having a representative,
“Ryan,” pose as an independent counselor capable of referring Plaintiffs to any number of drug
rehabilitation services.
85. Defendants’ extreme and outrageous conduct further consisted of devising the DRO Script
that was designed to provide the impression that an independent drug counselor was providing
meaningful analysis and education for someone seeking addiction services when, in reality, the
counselor was under the employ of Narconon and the prefabricated analysis merely was a tool to
channel the person to Narconon.
86. Defendants’ script was designed to manipulate persons like Claudia who were vulnerable
and seeking genuine help for a loved one. As a consequence of this manipulation, Defendants
deprived Plaintiffs of real choice in the process of selecting a drug rehabilitation facility.
87. Defendants detailed script and fake referral website amount to preying on persons
desperately seeking help for drug addiction.
88. Narconon International and ABLE, under the terms of their manual “Operating An
Effective Narconon Center” must approve all of an individual Narconon center’s websites.
Further, Narconon International coordinates and assists individual facilities in their marketing
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efforts and requires that all marketing be approved by Narconon International before
dissemination.
89. Defendants’ extreme and outrageous conduct continued when Sarah Burchett reached
Fresh Start. Defendants provided Sarah Scientology practices and rituals unrelated to substance
abuse treatment in lieu of providing her actual addiction treatment.
90. Defendants provide patients like Sarah Burchett Scientology rituals and practices with the
goal of recruiting for the Church of Scientology as evidenced, for example, by Exhibits F and G.
91. As a consequence of Defendants’ extreme and outrageous behavior, Sarah Burchett
required hospitalization for physical injuries and severe mental distress she suffered as a
consequence of the bizarre “treatments” to which she was subjected at Fresh Start.
FIFTH CLAIM FOR RELIEF
VIOLATIONS OF CALIFORNIA UNFAIR COMPETITION ACT,
Cal. Bus. & Prof. Code § 17200 et seq.
92. Plaintiffs incorporate by reference, as if fully set forth herein, each and every allegation set
forth in the preceding paragraphs and further allege as follows:
93. Defendants violated the California Unfair Competition Act numerous times in their
dealings with Plaintiffs. These violations included, without limitation, (i) setting up a fake referral
website; (ii) having a representative, “Ryan,” pose as an independent drug counselor capable of
referring to any drug rehabilitation program, when, in reality, the representative’s goal was to
channel the person to Narconon; (iii) using the DRO Script to manipulate Claudia Burchett into
thinking she was receiving actual analysis of her situation when, in fact, all education and analysis
she received about drug rehabilitation centers was scripted; (iv) Defendants’ false representations
that the Narconon program has a 76% success rate; (v) Defendants’ false representations that
Narconon’s sauna program has the ability to reduce or eliminate an addict’s drug cravings; (vi)
Defendants’ false representations to Plaintiffs that the Narconon program is secular when it
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actually consists entirely of Scientology practices and teachings unrelated to substance abuse
treatment.
94. Narconon International and ABLE control and approve Fresh Start’s advertising materials
and websites including the materials and websites used to defraud Plaintiffs.
95. Plaintiffs have been injured by relying on Defendants’ false advertisements. Members of
the public are likewise likely to be deceived by Defendants’ false and misleading advertising.
96. Defendants’ deceptive and unlawful business practices complained of herein continue to
this day. Defendants repeatedly have shown that they will continue engaging in these deceptive
and unlawful practices until they are judicially compelled to stop.
97. Accordingly, Plaintiff requests an injunction prohibiting Defendants from further engaging
in the false and deceptive practices complained of herein. Further, Plaintiffs request all relief
available to them under Cal. Bus. & Prof. Code § 17200 et seq.
DEMAND FOR JURY TRIAL
Plaintiffs demand a jury trial on all issues triable.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for the following relief:
A. Judgment in favor of Plaintiffs and against Defendants for damages in such amounts as
may be proven at trial;
B. Compensation for special, general, and treble damages;
C. Reasonable attorney’s fees and costs of suit;
D. Interest at the statutory rate;
E. Punitive or exemplary damages against Defendant;
///
///
///
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F. All further relief, both legal and equitable, that the Court deems just and proper.
DATED this July 16, 2014.
Respectfully submitted,

By:/s/ Ryan A. Hamilton
RYAN A. HAMILTON, ESQ.
CA BAR NO. 291349
HAMILTON LAW
5125 S. Durango Dr., Ste. C
Las Vegas, NV 89113
(702) 818-1818
(702) 974-1139
[email protected]

Attorney for Plaintiff
Case 3:14-cv-01678-BEN-RBB Document 1 Filed 07/16/14 Page 17 of 17

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