new at Scientology Lies: http://www.scientology-lies.com/sf-courts-lee-920407suit.html Andrew Lee v. Church of Scientology The Second Lawsuit On April 7, 1992, Andrew Lee sued the Church of Scientology of Los Angeles, the law office of Scientology attorneys Bowles and Moxon, Jeanne M. Gavigan (an attorney with Bowles & Moxon), and individual Scientology agents, listed as Does 1 through 10. The suit alleges fraud and breach of contract, claiming that Scientology did not intend to make the monthly payments they promised in their settlement agreement that caused Lee's first lawsuit to be dismissed. The confidential settlement agreement was filed as part of this second lawsuit. This second suit was dismissed with prejudice on August 5, 1992. While it is impossible to tell what happened from the court documents, it seems likely that Scientology settled the second suit, as well, since it's dismissed in the same manner as the first suit was. James C. Bridgman ASPELIN & BRIDGMAN 220 Montgomery Street, Suite 813 San Francisco, CA 94104 ATTORNEY FOR (NAME) Plaintiff Andrew Lee Superior Court, County of San Francisco City Hall 400 Van Ness Ave. San Francisco, CA. 94102
PLAINTIFF Andrew LEE
DEFENDANT CHURCH OF SCIENTOLOGY OF LOS ANGELES, LAW OFFICE BOWLES & MOXON, JEANNE M. GAVIGAN [X] DOES 1 TO 10


FILED SAN FRANCISCO COUNTY SUPERIOR COURT APR 7 1992
PLAN I STATUS CONFERENCE DATE: OCT 2 1992 8:30 AM

CONTRACT [X] COMPLAINT [ ] CROSS-COMPLAINT
CASE NUMBER 941967
1. This pleading, including attachments and exhibits, consists of the following number of pages: 14 2. a. Each plaintiff named above is a competent adult 3. a. Each defendant named above is a natural person [X] Except defendant (name): Church of Scientology [X] Except defendant (name) Law office Bowles & Moxon

COMPLAINT - Contract 4. [ ] 5. [ ] 6. This action is filed in this [x] county [ ] judicial district because a. [x] a defendant entered into the contract here 7. [ ] 8. [ ] 9. The following causes of action are attached and the statements above apply to each. (Each complaint must have one or more causes of action attached) [x] Breach of Contract [ ] Common Counts [x] Other (specify) Fraud 10. PLAINTIFF PRAYS For judgment for costs of suit, for such relief as is fair, just, and dquitable, and for [x] damages of $ 45,945.00 [x] interest on the damages [x] according to proof from (date): November 31, 1991 [x] attorney fees [ ] of $__________ [x] according to proof [x] other (specify): Value of case dismissed, according to proof Exemplary damages of $100,000.00 James C. Bridgman [signature]


SHORT TITLE: Lee vs. Church of Scientology ___ First ___ CAUSE OF ACTION - Breach of Contract Page __ 3 __ ATTACHMENT TO [X] Complaint [ ] Cross-Complaint (Use a separate cause of action form for each cause of action) BC-1. Plaintiff (name): Andrew Lee alleges that on or about (date): October 26, 1991 a [X] written [ ] oral [ ] other (specify) agreement was made between (name parties to agreement): Andrew Lee / Church of Scien- tology of Los Angeles, Law office Bowles & Moxon, Jeanne M. Gavigan [X] A copy of the agreement is attached as Exhibit A, or [ ] The essential terms of the agreement [ ] are stated in Attachment BC-1 [ ] are as follows (specify): BC-2. On or about (dates) defendant breached the agreement by [ ] the acts specified in Attachment BC-2 [ ] the following acts (specify) Defendant has not paid the $5,000.00 each month but has paid sporadically. BC-3. BC-4. Plaintiff suffered damages legally (proximately) caused by defendant's breach of the agreement [ ] as stated in Attachment BC-4 [x] as follows (specify): Damage amounts to 46,945 dollars plus interest. BC-5. [x] Plaintiff is entitled to attorney fees by an agreement or a statute [ ] of $ [X] according to proof.
CAUSE OF ACTION - Breach of Contract



SHORT TITLE: Lee vs. Church of Scientology ___ Second ___ CAUSE OF ACTION - Fraud Page __ 4 __ ATTACHMENT TO [X] Complaint [ ] Cross-Complaint (Use a separate cause of action form for each cause of action) FR-1. Plaintiff (name): Andrew Lee alleges that defendant (name): Church of Scientology of Los Angeles, Law office Bowles & Moxon, Jeanne M. Gavigan on or about (date): October 26, 1991 defrauded plaintiff as follows:
FR-2. [X] Intentional or Negligent Misrepresentation a. Defendant made representations of material fact [ ] as stated in Attachment FR-2a [X] as follows: That they would pay $5,000.00 each month. b. These representations were in fact false. The truth was [ ] as stated in Attachment FR-2b [X] as follows: They did not intend to pay $5,000.00 each month and have paid sporadically. c. When defendant made the representations, [X] defendant knew they were false, or [X] defendant had no reasonable ground for believing the representations were true d. Defendant made the representations with the intent to defraud and induce plaintiff to act as described in item FR-5. At the time plaintiff acted, plaintiff did not know the representations were false and believed they were true. Plaintiff acted in justifiable reliance upon the truth of the representations. FR-3. a. b. c. CAUSE OF ACTION - Fraud


__Second__ CAUSE OF ACTION - Fraud (Continued) Page __5__ FR-4. [X] Promise Without Intent to Perform a. Defendant made a promise about a material matter without any intention of performing it [ ] as stated in Attachment FR-4a [X] as follows: Defendants promissed plaintiff the amount of $ 5,000.00 each month in the contract with the intend to induce plain- tiff to dismiss an action against the Church of Scientology for damages. After dismissal of action defendants did in fact not pay. b. FR-5. In justifiable reliance upon defendant's conduct, plaintiff was induced to act [ ] as stated in Attachment FR-5 [X] as follows: Plaintiff dismissed an action against the Church of Scien- tology of Los Angeles. FR-6. Because of plaintiff's reliance upon defendant's conduct, plaintiff has been damaged [ ] as stated in Attachment FR-6 [X] as follows: Damage amounts to 46,945 dollars, plus interest Value of Claims in complaint that was dismissed, according to proof FR-7. Other:


Exemplary Damages Attachment Page _6_ ATTACHMENT TO [X] Complaint [ ] Cross-Complaint EX-1. As additional damages against defendant (name): Church of Scientology of Los Angeles, Law office Bowles & Moxon, Jeanne M. Gavigan Plaintiff alleges defendant was guilty of [ ] malice [X] fraud [ ] oppression as defined in Civil Code section 3294, and plaintiff should recover, in addition to actual damages, damages to make an example of and to punish defendant. EX-2. The facts supporting plaintiff's claim are as follows: see FR-4 (cause of action-fraud) and FR-2
EX-3 The amount of exemplary damages sought is a. [X] not shown, pursuant to Code of Civil Procedure section 425.10 b. [X] $ 100,000.00 Exemplary Damages Attachment
-- 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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