Fifth amended complaint Lisa McPherson Estate, Paragraph 34

McPherson estate, 21 December 1999

34. The extremis medical condition of LISA McPHERSON was obvious to SCIENTOLOGY and all of the individual Defendants. Yet, the Defendants, in total and conscious disregard for the rights of LISA McPHERSON, willfully, intentionally, wantonly, and maliciously towards the last days of her life decided to let LISA McPHERSON die, (i.e., "end cycle" in SCIENTOLOGY terms), rather than save her life even though her extremis physical condition was known to be entirely reversible and SCIENTOLOGY has no restrictions on seeking licensed professional care. This decision made by SCIENTOLOGY, through the SEA ORG by DAVID MISCAVIGE and carried out by KARTUZINSKI, JOHNSON, AND HOUGHTON was only due to their desire to protect SCIENTOLOGY from bad public relations.

Revised Fifth Amended Complaint Lisa McPherson Estate, Paragraph 34

All parties agreed with the change to the following in the revised version. In sofar we know removal of some offensive language took place, Schaeffer believes to be insufficiently founded in fact to be presented to a jury even as an expert opinion.

34. With knowledge that Lisa McPherson was in an extremis medical condition the last several days of her life, the Defendants, willfully, intentionally, maliciously and in total and reckless disregard for the health, rights, and safety of Lisa McPherson, did not seek timely needed emergency medical treatment.