United States District Court
District of Massachusetts

Deborah Khazei, pro se,
Plaintiff

vs.

Narconon of Northern California
First USA Bank,
Defendants

Civil Action No. 02-11776 GAO

COMPLAINT

INTRODUCTION

1) This is a complaint for return of monies on services not rendered; breach of contract; deceit; misrepresentation; fraud; violation of California consumer protection law; and compensatory damages for severe emotional and physical distress.

JURISDICTION

2) This Court has jurisdiction of the underlying action by reason of the present diversity of citizenship of parties, 28 U.S.C. 1331.

PARTIES

3) The Plaintiff, Deborah Khazei, is a resident of the State of Massachusetts and lives at 58 Beacon Street, Apartment [...], Boston, 02108.

4) The Defendant, Narconon of Northern California, is and was at all times relevant to this complaint, doing business within the state of California located at 8699 Empire Grade, Santa Cruz, Ca., 95060.

4) [sic] The Defendant, First USA Bank, is and was at all times relevant to this Complaint doing business within the State of California and presently has a business address of P.O. Box 15153, Wilmington, Delaware, 19886-5153.

FACTS

5) That on or about September, 1999, the Plaintiff became aware that the Defendant Narconon billed without Plaintiff's authorization and received from Defendant First Bank USA approximately $ 12,000 U.S. dollars for services not rendered.

6) That on or about September, 1999, the Plaintiff became aware that, without Plaintiff's authorization the Defendant First Bank USA rendered approximately $ 12,000 dollars to the Defendant Narconon in purported behalf of the Plaintiff.

7) That the Defendant First Bank USA either knew or should have known that the Plaintiff did not authorize any payment whatsoever to the Defendant Narconon.

8) That the Defendant First Bank USA either knew or should have known that the Plaintiff did not authorize payment to the Defendant Narconon in the amount paid.

9) That the Defendant Narconon made material misrepresentations of fact in order to obtain the Plaintiff's monies from Defendant First Bank USA.

10) That the conduct of Defendant Narconon as set forth herein this complaint was deceitful.

11) That the conduct of Defendant Narconon set forth herein this complaint was committed with fraudulent intent.

12) That the Defendant Narconon made material misrepresentations to the Plaintiff with regards to the quality and nature of the services rendered.

13) That the material misrepresentations of fact made to the Plaintiff by Defendant Narconon as set forth in paragraph 12 supra proximately caused the Plaintiff to suffer great emotional and physical distress.

FIRST CAUSE OF ACTION - PART I

13A) That the conduct of the part of both Defendants is and was a breach of contract.

FIRST CAUSE OF ACTION - PART II

14) The actions of the Defendant(s) set forth herein were illegal and in violation of the California Consumer Protection Law.

SECOND CAUSE OF ACTION

15) The actions of the Defendant Narconon set forth herein constituted fraud.

THIRD CAUSE OF ACTION

16) The actions of the Defendant Narconon set forth herein were misrepresentations.

FORTH [sic] CAUSE OF ACTION

17) The actions of the Defendant Narconon set forth herein constitute deceit.

FIFTH CAUSE OF ACTION

18) The conduct on the part of Defendant Narconon as set forth herein this complaint in paragraphs 12 and 13 supra, proximately caused the Plaintiff to suffer great and sever emotional and physical distress.

PRAYERS FOR RELIEF

19) Grant the Plaintiff all monies illegally obtained from the Plaintiff through Defendant First Bank USA by Defendant Narconon.

20) Grant the Plaintiff eight million U.S. Dollars in compensatory damages for suffering and severe emotional and physical distress as a proximate result of Defendant Narconon's conduct set forth supra in paragraph's 12 and 13.

21) Grant Plaintiff liberal amendment of this pro se complaint.

22) Grant Plaintiff interest on monies received by Defendant Narconon on behalf of the Plaintiff but not lawfully owed to the said Defendant Narconon.

23) Grant Plaintiff trial by Jury.

24) Grant Plaintiff such other and further relief as justice may require.

Dated Sept 4, 2002

Respectfully submitted,

[Signature]
Deborah Khazei, pro se
58 Beacon Street, Apt. [...]
Boston, MA. 02108