CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, STATE OF FLORIDA GENERAL CIVIL DIVISION
DELL LIEBREICH, as Personal
Representative of the
ESTATE OF LISA McPHERSON,
CHURCH OF SCIENTOLOGY d/b/a
CHURCH OF SCIENTOLOGY,
FLAG SERVICE ORGANIZATION, INC.,
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
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
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
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
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
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
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
Florida Bar No. 289698
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