new at Scientology Lies: http://www.scientology-lies.com/sf-courts-lee-910808suit.html ------------------------------------------------------- Andrew Lee v. Church of Scientology The First Lawsuit On August 8, 1991, Andrew Lee sued the Church of Scientology and several individual Scientology representatives, listed as Does 1 through 10. The suit alleges breach of contract, breach of covenant of good faith & fair dealing, fraud, conspiracy, and breach of fiduciary duty. JAMES C. BRIDGMAN Aspelin & Bridgman 220 Montgomery Street, Suite 811 San Francisco, CA 94104 Tel.: (415) 296-9812 Attorney for Plaintiff Andrew Lee


ANDREW LEE Plaintiff, v. CHURCH OF SCIENTOLOGY,
DOES I THROUGH X, inclusive Defendants
NO. 935411 COMPLAINT FOR BREACH OF CONTRACT, BREACH OF COVENANT OF GOOD FAITH AND FAIR DEALING, FRAUD AND CONSPIRACY, BREACH OF FIDUCIARY DUTY, ATTORNEY'S FEES. JURY TRIAL DEMANDED 1. Plaintiff ANDREW LEE is a residents of ths city and county of San Francisco. 2. Defendant CHURCH OF SCIENTOLOGY has its principal place of business in San Francisco, California. 3. Plaintiff is ignorant of the true names and capacities of Defendants sued herein as DOES I through X inclusive and therefore sue these Defendants by such fictitious names. Plaintiff will amend this complaint to allege their true names and capacities when ascertained. Plaintiffs are informed and believe and thereon alleges that each of these fictitiously named



Defendants is responsible in some manner for the occurrences herein alleged, and that Plaintiffs' damages as herein alleged were proximately caused by their conduct. 4. Plaintiff is informed and believes and thereupon allege that each Defendant is the agent, servant, and/or emploee of each other Defendant, and that in so doing the things hereinafter alleged, each Defendant was acting in the cause and scope of said Defendant's agency and employment. FACTS 4. On or about May 1989, Plaintiff contracted with Defendant for the receipt of services from Defendant to consist of a training course. Plaintiff paid Defendant $6,000 for said services and commenced a course in June 1989. During the training course, Plaintiff was given the impression that Defendant was a "good, clean outfit" and was induced to work for Defendant, discovering during the last week of July that he would be paid $30 to $50 a week. 5. Plaintiff was further influenced to pay $9,000 for trianing materials on July 30, 1989 and $15,000 for processing during the second week of August. After receiving some processing Plaintiff paid an additional $12,000 to complete said processing and to "go clear", a desired state among scientologists. He also was induced to promise to pay an additional $5,000 at a later date. 6. On or about August 1989, Plaintiff submitted a written request for official work leave from Defendant. As a result of this request Plaintiff was submitted to a "security check" which was designed to insure that he was aware of any overt acts he committed 2

against scientology and not commit any overt acts in the against scientology in the future. 7. Prior to leaving, Plaintiff decided to attempt to obtain the return of the money kept in "his" account with Defendant. Plaintiff was persuaded by Defendant to remain with Defendant and refused to tell him was he needed to do to get his money back. 8. Plaintiff was allowed to be "routed off" or not work for Defendant but was persuaded to do "conditions" which resulted in his staying with scientology. Plaintiff was then induced to join SEA ORG during the second week in September. SEA ORG is a part of Defendant, with a goal of promoting "ethics" throughout the world. 9. Plaintiff was persuaded not to inform his family of his involvement with Defendant. 10. On or about October 1989, Plaintiff again asked for leave for family reasons and was pressured into buying $15,000 worth of materials so that my request would go through. Plaintiff finally could stand it no longer and left SEA ORG without official leave on October 8, 1989. 11. Defendant continued to maintain a powerful hold over Plaintiff such that he returned to Defendant on October 9, 1989 and paid $5,000 to Defendant to fulfill his promise made during August. Defendants continued to pressure Plaintiff such that he was induced to sign up for an additional $32,000 worth of services. Defendant promised to help Plaintiff find a job and not to ask for more money. 12. However, they broke both promises and asked Plaintiff again for money in November 1989. On the same day in November 1989, 3

one of Defendant's agents pulled Plaintiff's wallet out of his pocket and took out his credit card. Plaintiff asked for his credit card back and said not to charge anything on it. He was told that Defendant was only checking his credit line. This was a lie. Two charges showed up on Plaintiff's credit card, one for $1000 and one for $500. 13. During the second week of October 1989, Plaintiff was found by SEA ORG and attempted to leave several times. He did not want to do "conditions" again because that is what kept him in scientology the first time. Again he was persuaded into doing "conditions" and required to go through another security check. This process again persuaded Plaintiff to remain with scientology. He was required to remain on the Estate Planning Force, which was part of SEA ORG, which is responsible for cleaning duties, and to live near Defendants place of business in Los Angeles. After three and a half week he decided to leave but was again persuaded to stay with Defendant and in the process was induced to give them $1500 from his credit card. 14. On or about November 20, 1989, Plaintiff was induced to give his TRW stock to Defendant in order to go "clear". Fortunately, Defendant was unable to cash the check made out to Plaintiff from the sale of the stock. He was able to negotiate the return of most of the money from the sale of the stock. 15. What finally allowed Plaintiff to regain control of his life was that his sister accompanied him to Defendant's location and made him realize that Defendant was controlling his life and taking his money. 4

FIRST CAUSE OF ACTION PLAINTIFF V. DEFENDANT SCIENTOLOGY Breach of Contract 16. Plaintiffs reallege and incorporate by reference the allegations set forth in paragraphs 1 through 15 of this complaint as against Defendant. 17. Defendant entered into said contract with Plaintiff knowing that it had a separate agenda, namely to induce Plaintiff to give as much of his wealth as possible to Defendant. Plaintiff received only a fraction of the services and material which he was entitled to receive and was exposed to the constant pressure to give Defendant money. Plaintiff was further subjected to what amounted to "brain washing" so that Defendant could obtain Plaintiff's money. 18. Defendant breached its obligations under the contract to Plaintiff as described in paragraph 17 and in so doing caused Plaintiff to be severely damaged both financially and emotionally. Wherefore: Plaintiff claims judgment and damages as set forth in his prayer for relief. SECOND CAUSE OF ACTION PLAINTIFF V. DEFENDANT SCIENTOLOGY Breach of Covenant of Good Faith and Fair Dealing 19. Plaintiffs reallege and incorporate by reference the allegations set forth in paragraphs 1 through 18 of this complaint as against Defendant. 20. Defendant's contract with Plaintiff raises an implied covenant of good faith and fair dealing which it broke repeatedly in that it intentionally deceived Plaintiff into giving his money 5

and property to Defendant. He was psychologically handled such that every time he gave money he was made to feel better. Plaintiff was an indecisive person who was manipulated to obtain his money. Wherefore: Plaintiff claims judgment and damages as set forth in his prayer for relief. THIRD CAUSE OF ACTION PLAINTIFF V. DEFENDANT SCIENTOLOGY Fraud and Conspiracy 21. Plaintiffs reallege and incorporate by reference the allegations set forth in paragraphs 1 through 20 of this complaint as against Defendant. 22. Defendant intentionally, willfully and wantonly engaged in the acts enumerated in paragraph 17 with the purpose of deceiving Plaintiff and inducing himi to part with his money and property. 23. Plaintiffs are entitled to exemplary and punitive damages for Defendant's fraudulent conduct in the sum of $100,000. Wherefore: Plaintiff claims judgment and damages as set forth in his prayer for relief. FOURTH CAUSE OF ACTION PLAINTIFF V. SCIENTOLOGY Breach of Fiduciary Duty 24. Plaintiffs reallege and incorporate by reference the allegations set forth in paragraphs 1 through 18, and 20 through 23 of this complaint as against Defendant. 25. Defendant owed a fiduciary duty to Plaintiff and breached that duty as set forth in paragraphs 17 of this complaint. Not only did Defendant keep money in an account on 6

complaint. Not only did Defendant keep money in an account on behalf of Plaintiff, without the intention of giving it back, its did not give it back. Defendant supports its actions by claiming it is a church. That in itself entails a confidential and fiduciary relationship. 26. As a direct and proximate result of that breach of duty, Plaintiff was damaged in a sum in excess of $15,000. Wherefore: Plaintiff claims judgment and damages as set forth in his prayer for relief. PLAINTIFFS' PRAYER FOR RELIEF Wherefore Plaintiff prays judgement and damages of each and every Defendant jointly and severally as follows: 1. For the sum of $35,000 as against Defendant for breach of contract, any damages in excess of that amount to be proven at trial. 2. For a sum to be proven at trial as against Defendant for the Second and Fourth Causes of action as exemplary and punitive damages. 3. For interest on said sums at the legal rate of interest. 4. For reasonable attorney's fees. 5. For costs of the suit. 6. For such other relief as this Court finds just and equitable. Dated: August 8, 1991 [signature] JAMES C. BRIDGMAN Aspelin & Bridgman Attorneys for Plaintiff 7

VERIFICATION I, ANDREW LEE, am the plaintiff in this action. I have read the foregoing document and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein stated on information and belief, and as to those matters, I believe them to be true. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that this declaration was executed on APRIL 17, 1991, at San Francisco, California. [signature] ANDREW LEE
-- Kristi Wachter the activist formerly known as "Jour" (before $cientology outed me) If I am not who you say I am, then you are not who you think you are. - James Baldwin I think $cientology is hurting people and breaking the law, and I want them to stop it. See http://www.scientology-lies.com for more.

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