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

[...] (h) That at 11;00 o'clock P.M., on said 23rd day of February, 1951, said Hubbard, together with defendant Frank B. Dessler, head of the Los Angeles Dianetic Foundation, abducted the infant child of the parties, Alexis from her crib, and deposited said infant in West Los Angeles with defendant Vince Mc Gonigle under the assumed name of Anne Marie Olson, and concealed said infant from plaintiff until this day. That this was admitted by said Dessler in the habeas corpus proceedings filed on the 10th day of April, 1951 entitled In re Alexis Valorie Hubbard, Los Angeles Superior Court Number H.C. 35879.

(i) That said Hubbard, Dessler and defendant Richard B. De Mille, having secreted said infant child, feloniously dragged plaintiff out of her bed attired only in her night gown, it then being 1:00 o'clock A.M., of the morning of the 24th day of February, 1951, and by the use of threats, strangulation, torture, and false promises to return her child to her, carried and kidnapped plaintiff to Yuma, Arizona, all as is detailed at length in the habeas corpus proceeding above mentioned.

(j) That plaintiff has ever since sought the whereabouts of her infant child, and has consulted attorneys, police, sheriffs, Federal Bureau Of Investigation agents, and courts, and has brought said habeas corpus proceedings; that said Hubbard and his attorneys refuse any information as to the whereabouts of her infant child, unless she goes back to live with said Hubbard, an alternative that means certain continued torture and possible death, a predicament no good woman, wife and mother should have to face.

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