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Deborah Khazei vs. Narconon of Northern California
United States District Court
Deborah Khazei, pro se,
vs.
Narconon of Northern California
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]
The name "Narconon"® is trademarked to the Scientology
organization through one of their many front groups. The name
"Scientology"® is also trademarked to the "Church"
of Scientology. Neither this web page, nor this web site, nor any of the
individuals mentioned herein assisting to educate the public about the
dangers of the Narconon scam are members of or representitives of the
Scientology organization.
If you or a loved one needs help -- real help -- there are
a number of rehabilitation programs you can contact. The real
Narcotics Anonymous organization
can get you in touch with real people who can help you.
Click [HERE] to visit Narcotivs
Anonymous's web site. Narcotics Anonymous's telephone number is
1 (818) 773-9999.
Return to The NarCONon exposure's main Index page.
District of Massachusetts
Plaintiff
First USA Bank,
Defendants
Deborah Khazei, pro se
58 Beacon Street, Apt. [...]
Boston, MA. 02108
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