SUPERIOR COURT OF THE STATE OF CALIFORNIA

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

| THOMAS CRUISER MAPOTHER IV, | Case No.: [To be assigned] | | Plaintiff, | | | v. | COMPLAINT FOR DAMAGES | | DAVID MISCAVIGE, Individually and as Chairman of the Board of the Religious Technology Center, and DOES 1-50, | (1) False Imprisonment | | Defendants. | (2) Intentional Infliction of Emotional Distress (IIED) | | | (3) Fraudulent Inducement | | | (4) Unjust Enrichment |

INTRODUCTION AND NATURE OF THE ACTION

1. This is an action for damages brought by Plaintiff THOMAS CRUISER MAPOTHER IV (“Plaintiff”) against Defendant DAVID MISCAVIGE (“Defendant Miscavige”) and others, arising from decades of psychological manipulation, financial exploitation, and severe physical and emotional confinement endured by Plaintiff while a member of the Church of Scientology, culminating in forced, illegal isolation within a physical restriction area known internally as “The Hole.”
2. Plaintiff seeks recovery for substantial damages, including but not limited to, recovery of millions of dollars paid to Scientology organizations, physical and emotional trauma, lost earning capacity, and deprivation of personal liberty caused directly by the intentional, malicious, and unlawful acts of the Defendants.

PARTIES

3. Plaintiff THOMAS CRUISER MAPOTHER IV is and at all relevant times was an individual residing in the State of California.
4. Defendant DAVID MISCAVIGE is and at all relevant times was an individual who exercises ultimate authority and control over the Church of Scientology and its related corporate entities, including the Religious Technology Center, and is sued herein both individually and in his capacity as the final policymaker and controller of the organizations.
5. The true names and capacities of Defendants DOE 1 through DOE 50, inclusive, whether corporate, association, or individual, are unknown to Plaintiff, who therefore sues these Defendants by such fictitious names. Plaintiff is informed and believes, and thereon alleges, that each of the fictitiously named Defendants is responsible in some manner for the occurrences and damages alleged herein. Plaintiff will amend this Complaint to reflect their true names and capacities when ascertained.

JURISDICTION AND VENUE

6. This Court has subject matter jurisdiction over this action because the matter in controversy exceeds the minimum jurisdictional limits of this Court.
7. Venue is proper in the County of Los Angeles, State of California, because the Plaintiff resides in this County, and a substantial portion of the Defendants’ wrongful conduct causing injury to Plaintiff occurred within this County.

FACTUAL ALLEGATIONS

8. Plaintiff was induced to join the Church of Scientology (hereafter, the “Church”) based on false promises and representations that the organization offered unique, beneficial, and indispensable self-improvement services.
9. From the 1990s through the 2010s, Plaintiff dedicated substantial time, energy, and resources, including millions of dollars in fees, contributions, and donations, to the Church and its affiliated entities, all under the direct or indirect control of Defendant Miscavige.
10. The vast sums of money paid by Plaintiff were premised on the fraudulent representation that the services purchased (known as “auditing” and “training”) were scientifically valid and would yield guaranteed spiritual and life-altering benefits, which they did not.
11. Defendant Miscavige, in his capacity as the highest authority, personally orchestrated and approved various policies and practices designed to control, manipulate, and financially exploit high-profile members like Plaintiff.
12. A crucial element of this control structure was the use of institutional isolation and physical confinement to discipline and punish senior Church members and staff who were perceived as disloyal or inefficient by Defendant Miscavige.
13. Specifically, Plaintiff was subjected to extended periods of involuntary confinement within an area known as “The Hole.” “The Hole” is not a formal rehabilitation or training center, but a restricted, heavily monitored, and unsanitary office space within the organization’s Gold Base in Riverside County, California, or similar facilities.
14. During the period of confinement, Plaintiff was prohibited from leaving the premises, denied communication with the outside world, subjected to continuous humiliation, verbal abuse, and forced participation in bizarre group disciplinary practices.
15. This confinement was often executed without Plaintiff’s free and informed consent, was physically and psychologically coercive, and amounted to false imprisonment. Defendant Miscavige personally participated in, directed, or had full knowledge of and ratified the decision to confine Plaintiff.
16. The conditions and duration of the confinement were extreme and outrageous, far exceeding the bounds of decency in a civilized society, and were intentionally designed by Defendants to inflict severe emotional distress upon Plaintiff to compel his conformity and silence.

FIRST CAUSE OF ACTION

(False Imprisonment)

17. Plaintiff incorporates by reference the allegations contained in paragraphs 1 through 16.
18. Defendants, and each of them, intentionally, unlawfully, and without consent or legal justification, restrained Plaintiff’s personal liberty by confining him within “The Hole” for extended periods.
19. Plaintiff was aware of his confinement and restraint.
20. As a direct and proximate result of the Defendants’ false imprisonment, Plaintiff suffered severe damages, including loss of liberty, economic loss, and severe emotional distress.

SECOND CAUSE OF ACTION

(Intentional Infliction of Emotional Distress (IIED))

21. Plaintiff incorporates by reference the allegations contained in paragraphs 1 through 20.
22. Defendants, and each of them, engaged in extreme and outrageous conduct by orchestrating and maintaining Plaintiff’s forced isolation, subjecting him to humiliation, abuse, and deprivation within “The Hole,” and employing manipulative techniques over many years.
23. Defendants’ conduct was done with the intent of causing, or with reckless disregard of the probability of causing, severe emotional distress to Plaintiff.
24. Plaintiff suffered, and continues to suffer, severe emotional distress, anxiety, fear, and psychological injury as a direct and proximate result of Defendants’ outrageous conduct.

THIRD CAUSE OF ACTION

(Fraudulent Inducement)

25. Plaintiff incorporates by reference the allegations contained in paragraphs 1 through 24.
26. Defendants, and their agents, made representations of material fact to Plaintiff regarding the benefits, purpose, and spiritual necessity of the services purchased, including the promise of “spiritual freedom” and “higher consciousness.”
27. These representations were false, and Defendants knew they were false at the time they were made, or made them recklessly without regard for the truth.
28. Defendants made these false representations with the intent to induce Plaintiff to rely on them and to expend vast sums of money and time.
29. Plaintiff justifiably relied on these representations, leading to the substantial financial and personal investment described herein.
30. As a direct and proximate result of Defendants’ fraud, Plaintiff has suffered economic damages in the amount of all fees and contributions paid to the Church and its entities, the exact amount to be proven at trial.

FOURTH CAUSE OF ACTION

(Unjust Enrichment)

31. Plaintiff incorporates by reference the allegations contained in paragraphs 1 through 30.
32. Plaintiff conferred significant monetary benefits and services upon Defendants by paying millions of dollars in fees, contributions, and labor.
33. Defendants accepted and retained these benefits and services with the knowledge that they were obtained through false pretenses, coercion, and fraudulent inducement, as detailed above.
34. Retention of these funds and benefits by Defendants would be inequitable and unconscionable.
35. Plaintiff is therefore entitled to restitution of all funds, contributions, and the reasonable value of services provided to Defendants, to prevent their unjust enrichment.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff THOMAS CRUISER MAPOTHER IV prays for judgment against Defendants DAVID MISCAVIGE, Individually and as Chairman of the Board of the Religious Technology Center, and DOES 1-50, and each of them, as follows:

1. For General Damages in an amount to be determined by the jury at trial.
2. For Special Damages, including restitution for all fees, contributions, and donations paid to the Church of Scientology and its affiliated entities.
3. For Punitive and Exemplary Damages in an amount sufficient to punish Defendants and deter similar conduct in the future, due to Defendants’ willful, malicious, and oppressive conduct.
4. For Prejudgment and Post-judgment Interest as provided by law.
5. For Costs of Suit incurred herein.
6. For such other and further relief as the Court deems just and proper.

DATED: [Current Date]

AXISLAW.SITE By: /s/ [JCJ] [Joseph Christian Jukic & Michael Matthew Jukic] Attorneys for Plaintiff THOMAS CRUISER MAPOTHER IV