DELL LIEBREICH, as Personal Representative of the ESTATE OF LISA McPHERSON,

Plaintiff,

vs. Case No.
Section
CHURCH OF SCIENTOLOGY d/b/a
CHURCH OF SCIENTOLOGY,
FLAG SERVICE ORGANIZATION, INC., COMPLAINT
FOR WRONGFUL
DEATH AND
DEMAND FOR
Defendant. TRIAL BY
JURY

_________________________________/

COMES NOW the Plaintiff, DELL LIEBREICH, as Personal Representative of the ESTATE OF LISA McPHERSON, by and through her undersigned attorney and sues the Defendant, CHURCH OF SCIENTOLOGY d/b/a CHURCH OF SCIENTOLOGY, FLAG SERVICE ORGANIZATION, INC., and alleges:

1. This is an action for damages for wrongful death pursuant to Florida Statutes, =A7768.16, et seq., known as "Florida Wrongful Death Act."

2. The damages in this action greatly exceed this court's threshold jurisdiction of $15,000.00 and Plaintiff hereby places Defendant on notice that it will seek an evidentiary hearing pursuant to the Florida Rules of Civil Procedure to amend this Complaint to seek substantial punitive damages in addition to compensatory damages pursuant to the allegations set forth below.

3. LISA McPHERSON was at all material times herein a resident of Clearwater, Pinellas County, Florida, and survived by her biological mother, FANNIE B. McPHERSON. There were no other survivors under Florida law.

4. DELL LIEBREICH, maternal aunt of LISA McPHERSON, has been appointed as the Personal Representative of the ESTATE OF LISA MCPHERSON as evidenced by the Letters of Administration dated February 4, 1997, and attached hereto as Exhibit "A."

5. At all times material herein, the Defendant, CHURCH OF SCIENTOLOGY d/b/a CHURCH OF SCIENTOLOGY, FLAG SERVICE ORGANIZATION, INC. is a management church of the collection of unincorporated organizations and a multitude of corporations within a nominal corporate structure collectively known as the CHURCH OF SCIENTOLOGY, where each nominal corporation or organization is the alter ego of the other, comprised of similar officers and directors with disregard of corporate structure doing business under many names such as INTERNATIONAL ASSOCIATION OF SCIENTOLOGISTS, CHURCH OF SPIRITUAL TECHNOLOGY, SEA ORG and RELIGIOUS TECHNOLOGY CENTER, doing business throughout the state of Florida, with offices located in Hillsborough County and Pinellas County, Florida, as well as throughout the world under the above names and other names of which LISA McPHERSON was a member. The Defendant, CHURCH OF SCIENTOLOGY d/b/a CHURCH OF SCIENTOLOGY, FLAG SERVICE ORGANIZATION, INC., (hereinafter referred to as CHURCH OF SCIENTOLOGY), delivers the highest level of Scientology services, training and auditing, including a technique known as "Introspection Rundown".

6. On or about November 18, 1995, LISA McPHERSON was operating a motor vehicle in Clearwater, Florida, and was involved in an extremely minor motor vehicle accident wherein she sustained no injuries. However, upon exiting her motor vehicle, she requested help by stating to emergency personnel, "I NEED HELP," I NEED TO TALK TO SOMEONE," with a fixed stare while exhibiting unusual behavior indicating the need for emergency medical and psychological treatment.

7. On that date, LISA McPHERSON was transferred by ambulance to the Morton Plant Hospital located in Clearwater, Florida, where she sought and received emergency medical and psychological treatment.

8. Shortly after arriving at Morton Plant Hospital, the CHURCH OF SCIENTOLOGY members observed that LISA McPHERSON'S vehicle was involved in a motor vehicle accident.

9. Members of the CHURCH OF SCIENTOLOGY appeared at Morton Plant Hospital on November 18, 1995 and convinced LISA McPHERSON to leave with them and return to the CHURCH OF SCIENTOLOGY headquarters.

10. After repeated assurances by the members of the CHURCH OF SCIENTOLOGY that they would provide 24-hour care to LISA McPHERSON, Morton Plant Hospital reluctantly and against their own medical advice released LISA McPHERSON from Morton Plant Hospital, placing LISA McPHERSON in the exclusive care, custody and control of the CHURCH OF SCIENTOLOGY.

11. Immediately after leaving Morton Plant Hospital, members of the CHURCH OF SCIENTOLOGY transported LISA McPherson back to the Ft. Harrison Hotel, the spiritual headquarters of the CHURCH OF SCIENTOLOGY in Clearwater, Pinellas County, Florida.

12. At the said headquarter facilities, the CHURCH OF SCIENTOLOGY , by and through their agents, representatives, employees, and/or other members, systematically began a series of techniques in following their own policies of THE CHURCH OF SCIENTOLOGY which included, but is not limited to, the technique known as "Introspection Rundown". This involved in part the total isolation of LISA McPHERSON in a room against her will.

During her confinement, LISA McPHERSON slipped into a coma,. The care givers of the CHURCH OF SCIENTOLOGY permitted LISA McPHERSON to remain in a coma for an extended period of time which resulted in severe dehydration and ultimately her death, even though it was obvious that while in a coma she needed nutrition, liquids and urgent medical care and treatment.

13. The above actions of the Defendants were carried out by medically untrained and unlicensed personnel of the CHURCH OF SCIENTOLOGY pursuant to the CHURCH OF SCIENTOLOGY'S own internal policies, procedures, and bulletins.

14. LISA McPHERSON remained in the exclusive care, custody and control of the CHURCH OF SCIENTOLOGY from the moment she left the Morton Plant Hospital to the time she arrived at Columbia/HCA New Port Richey Hospital on December 5, 1995.

15. Prior to deciding to take LISA McPHERSON to a hospital while she remained in the defendant's exclusive care, custody, and control, the members of the CHURCH OF SCIENTOLOGY willfully, intentionally , maliciously and as a result of their members culpable negligence ignored her medical condition which required urgent medical care.

16. On or about December 5, 1995, the CHURCH OF SCIENTOLOGY, after observing LISA McPherson in an unconscious state and severely dehydrated for several days, decided for the first time to seek professional medical help and rather return her to the nearest medical facility, Morton Plant Hospital, drove her to a hospital some 20 miles away in their private van, rather than an ambulance, where the emergency room physician, a fellow Scientologist, was located.

17. The above actions of the CHURCH OF SCIENTOLOGY lasted a total of 17 days which resulted in the death upon arrival of LISA MCPHERSON on December 5, 1995, at Columbia/HCA New Port Richey Hospital due to extreme bed rest and extreme dehydration.

18. The above actions of the CHURCH OF SCIENTOLOGY were the result of their premeditated design to follow their techniques, bulletins, and procedures, which was performed willfully, intentionally, maliciously and in total disregard of the rights of LISA MCPHERSON in addition to their culpable negligence and gross negligence in failing to obtain timely appropriate emergency medical care through licensed medical providers.

WHEREFORE, the Plaintiff, DELL LIEBREICH, as Personal Representative of the ESTATE OF LISA McPHERSON, demands judgment against the Defendant, CHURCH OF SCIENTOLOGY, FLAG SERVICE ORGANIZATION, INC., inclusive of any and all other organizations operating under the umbrella name of CHURCH OF SCIENTOLOGY, jointly and severally, together with costs and other relief as the court may deem just in the premises and demands trial by jury.

__________________________ __________

KENNAN G. DANDAR, ESQ.
DANDAR & DANDAR, P.A.
[deletions]
Florida Bar No. 289698