[Stamped: D414408] COMES NOW the plaintiff and for cause of action against defendants alleges and says:

[...] That said Hubbard departed from the State of California on the 24th day of February, 1951, and ever since has remained out- side of California, for the purpose of evading the process of the Court, and for the purpose of attempting to deprive plaintiff of her marital rights herein; that said absence from the State on the part of said Hubbard was and is for the purpose of resisting plaintiff's efforts to enforce her said rights against said defendant for support and maintenance for herself and her child and to obtain an equitable division of the community property of the parties; that said Hubbard has repeatedly threatened that he would stay out of California so as to make it impossible for her to get any money or support from him and to prevent her from sharing in the community property of the parties, and said Hubbard has stated that he would do everything in his power to deprive plaintiff. of all of her said marital rights; that plaintiff is informed and believes, and upon such information and belief, alleges that pursuant to said threats, said Hubbard has concealed various community assets, and has placed said assets in the name of Hubbard Dianetics Research Foundation, and in the names of the other defendants named herein, and in the names of other persons unknown to the plaintiff that said Hubbard will continue to further hide and conceal said community property assets from plaintiff unless prevented from doing so by the appointment of a receiver herein; that by reason of the said acts of said Hubbard, plaintiff has been compelled to exhaust her own personal estates and to draw upon her family for support; that by reason thereof, plaintiff is without adequate funds for her own support or the support of her child, or to prosecute this action; that all of the acts heretofore set forth on the part of said Hubbard were perpetrated intentionally and willfully and for the express purpose of defrauding plaintiff of her said marital rights, and to unjustly and fraudulently deprive plaintiff of any and all of her rights whatsoever, and to render her helpless and subject to his complete and arbitrary will and domination.

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