:IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL : CIRCUIT :IN AND FOR HILLSBOROUGH COUNTY, STATE OF FLORIDA :GENERAL CIVIL DIVISION : 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 : TRIAL BY : Defendant. : 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, section 7768.16, 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 persisting in their attempt to : subdue the will of LISA McPHERSON so that she would succumb : to the will of the CHURCH OF SCIENTOLOGY. [point 18 duplicated in original] : 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. : 1009 North O'Brien Street : Post Office Box 24597 : Tampa, Florida 33623-4597 : 813-289-3858/FAX: 813-287- : 0895 : Florida Bar No. 289698