FILED Mar 4, 1985
Howard Hanson, Marin County Clerk
By K. Guy, Deputy

Law Office of David L. Cunningham
Attorney for Plaintiff
Beverly Jacobs O'Mahony

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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF MARIN

BEVERLY JACOBS O'MAHONY, an individual, Plaintiff, vs. FRANKLIN JONES, aka DA FREE JOHN, aka BUBBA FREE JOHN, an individual; JOHANNINE DAIST COMMUNION, alleged charitable and religious non-profit organization; BRIAN O'MAHONY; WILLIAM TSIKNAS; PATRICIA TSIKNAS; LYNN CLOSSER; VINCENT GODDARD; LARRY HASTINGS; JOHN ANDREWS; and DOES 1-100, individuals; DOES 101-105, Black and White partnerships; and DOES 106-110, Red and Green Corporations, Defendants.

NO 121999

COMPLAINT FOR DAMAGES: UNDUE INFLUENCE; INTENTIONAL MISREPRESENTATION; FRAUD; DECEIT; NEGLIGENT MISREPRESENTATION; INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS; FALSE IMPRISONMENT; CORPORATION ALTER EGO OF FRANKLIN JONES; ASSAULT, ASSAULT AND BATTERY; BREACH OF DIRECTOR'S DUTY; MALPRACTICE OF CLERGY; AND INVOLUNTARY SERVITUDE

SUMMONS ISSUED

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1. Plaintiff, the product of a broken home, was living alone in New York City while attending the university. She was a young, naive, impressionable and very lonely girl.

2. While Plaintiff was residing in New York City, she became acquainted with the "religious teachings" as espoused by Defendants, FRANKLIN JONES and the JOHANNINE DAIST COMMUNION. Plaintiff came in contact with several "followers" of this "religion".

3. Plaintiff was told by the "followers" of this religious doctrine that their leader, Defendant FRANKLIN JONES, was of "free birth" and an "incarnation of God", and that through his teachings "Spiritual Bliss" could be attained.

4. Over a prolonged period of time, Plaintiff was strongly influenced and trusted and completely controlled by these "followers" of the "religion" preached by Defendant, FRANKLIN JONES, and was induced and persuaded by these religious zealots into allowing them to move into her residence. After several months of residing in Plaintiff's home, there was a gradual taking-over of personal property of Plaintiff, until the "followers" were exercising full control over Plaintiff and all her personal property.

5. The "followers", through prolonged psychological manipulation and intimidation, were able to persuade Plaintiff that she needed them and would be ostracized by them if she did not obey their wishes and follow their demands.

6. Among part of the teachings of this new-found "religion" was that all personal property belonged to the group and not to the individual; consequently, all personal property belonging to Plaintiff was absorbed into the religious order.

7. After many months of continued manipulation, subtle persuasion and intimidation, Defendant FRANKLIN JONES informed the group that there would be an exodus to California, and demanded that his "followers" leave New York and move to San Francisco. Throughout the period in which the move took place, and after settling in San Francisco, Plaintiff was always accompanied and watched over by "followers" of the "religion".

8. During his early period in San Francisco, Plaintiff met and subsequently married Defendant, BRIAN O'MAHONY, who was, at the time of initial contact, the Financial Coordinator of the JOHANNINE DAIST COMMUNION. After the marriage took place, Plaintiff and Defendant, BRIAN O'MAHONY, lived in a communal environment with six other couples, in San Francisco, California.

9. Immediately following the wedding, Plaintiff was beaten regularly by the Defendant, BRIAN O'MAHONY, with the support and backing of the remaining members of the commune. The woman's status in the commune, and under the teachings proclaimed by Defendant, FRANKLIN JONES, was that of servant, or slave, compelled to follow the opinions or decisions of the men, and any punishment determined by the men for disobedience was considered appropriate and encouraged by FRANKLIN JONES.

10. All money, goods or belongings received by Plaintiff was immediately taken and confiscated with the majority of the funds going to the JOHANNINE DAIST COMMUNION, and a small portion retained for the use of the commune.

11. Plaintiff, upon arriving in San Francisco in 1976, was hired as a professional musician by the San Francisco Symphony Orchestra, with her entire income being forfeited to the JOHANNINE DAIST COMMUNION. However, in a short period of time, Plaintiff was no longer allowed by the "followers" to pursue her musical endeavors, and was relegated to performing household chores in the commune. Plaintiff was not permitted to associate with any one outside the religious order, and was encouraged and required to read the various matter written by Defendant, FRANKLIN JONES. In addition, no one was allowed within the communal house unless they were "followers" of the "religious doctrine", as preached by Defendant, FRANKLIN JONES.

12. Plaintiff was kept under the control of the "followers" and forced to live within the narrow confines as set forth by the teaching of Defendant, FRANKLIN JONES, including, but not limited to, strict diet, forbearance of all personal property which was turned over to Defendant, JOHANNINE DAIST COMMUNION, and strict use of time consisting of service work, study groups and devotional meetings.

13. Plaintiff was assaulted and physically abused for any deviation of the rules, and dictated by Defendant, FRANKLIN JONES. Plaintiff sustained bruises, abrasions and broken bones at the hands of Defendant, BRIAN O'MAHONY, at the command and direction of Defendant, FRANKLIN JONES, for any slight deviations from the rules as set forth by Defendant, FRANKLIN JONES.

14. Plaintiff was under constant surveillance by members of the commune in which she lived, as well as by other members of the JOHANNINE DAIST COMMUNION.

15. Plaintiff was undergoing a period of brainwashing wherein she was constantly told not to trust her own feelings as "these feelings were just ego, and ego would lead to a conventional life", but to absolutely trust the teachings of Defendant FRANKLIN JONES.

16. Plaintiff was constantly being instilled with the fact that she would attain "Spiritual Bliss" by following the strict rules and teachings of Defendant, FRANKLIN JONES, and that she should feel uncomfortable with these rules and teachings as she was supposed to feel the "spiritual heat" which signified that she was on the spiritual path, and that this was the only way to find "Spiritual Bliss". It was expected that a lot of discomfort was to be felt along the way.

17. Although Plaintiff was extremely uncomfortable, and quite concerned for her well-being, she never questioned leaving the group, because the rules set forth by Defendant, FRANKLIN JONES, were the path by which God could be found and "Spiritual Bliss" attained, which is what Plaintiff had initially been looking for.

18. When Plaintiff became pregnant with her first child, strict dietary restrictions were enforced, as well as severe working conditions. Plaintiff became so ill that she was confined to bed rest for the last trimester of her pregnancy.

19. Plaintiff's first child was born with serious physical impairments, causing Plaintiff to suffer from anxiety and emotional distress. Plaintiff's impoverished situation required her to seek assistance from her father in the form of baby clothes and other articles other than money, as any monies would be taken by the JOHANNINE DAIST COMMUNION.

20. Subsequently, Plaintiff's father purchased a house, furniture and household equipment in Marin County for Plaintiff, in order that she may live apart from the "followers" of the JOHANNINE DAIST COMMUNION: however, once the house was purchased, Defendant, BRIAN O'MAHONY constantly held "religious" meetings and invited groups of "followers" to stay at the house, and demanded that Plaintiff clean the house and cook meals for the "followers", as well as take care of their child.

21. Plaintiff became pregnant for a second time, as a result of a rape by Defendant, BRIAN O'MAHONY, and soon thereafter, two couples from the JOHANNINE DAIST COMMUNION moved into Plaintiff's home. Plaintiff was required to maintain the house, and care for her two-year old child, as well as to cook all meals for all the inhabitants soon after their second child was born.

22. Defendant, BRIAN O'MAHONY, continued to physically abuse Plaintiff even after the birth of her second child. Approximately one year after the birth of her second child, Plaintiff became pregnant again, and was promised by Defendant, BRIAN O'MAHONY, the sum of Fifty Thousand Dollars ($50,000.00) if she would have the child. Plaintiff had anticipated that this money could be used for the well-being of the children, and agreed to the offer; however, just prior to the birth of her third child, said Defendant reneged on his offer and stated that he had no intention of paying her anything to have the child. Plaintiff's father, upon hearing that a third child was on the way, acquired a bigger house to accommodate his daughter's family.

23. After moving into the new house, Defendant, JOHANNINE DAIST COMMUNION opened an office on the premises, from which they conducted their daily business, once again forcing Plaintiff into the position of "house slave".

24. Defendant, JOHANNINE DAIST COMMUNION, has been organized and set up as a Non-Profit Religious Corporation in the State of California; however, said Defendant is merely an alter-ego of Defendant, FRANKLIN JONES, as an extremely large percentage of the funds are used by said individual for his personal wants and desires. In 1982, Defendant, JOHANNINE DAIST COMMUNION, acquired Translation Island in Fiji for approximately Two and One-Half Million Dollars ($2,500,000.00), and set up a community comprised of the "inside followers" of Defendant, FRANKLIN JONES.

25. Defendant, BRIAN O'MAHONY, who was now Chief Executive Officer of the JOHANNINE DAIST COMMUNION, was required to spend a good deal of his time in Fiji. During the latter part of 1983, Plaintiff was forced and coerced to join her husband in Fiji, and subsequently, left her three children in Marin County and went to Fiji. Once in Fiji, Plaintiff was continually and persistently ridiculed and humiliated by all the named Defendants. She was forced to consume alcohol which had never been allowed, according to the teachings and dictates of Defendant, FRANKLIN JONES, and was required to partake in various sexual acts commanded by "the Master", Defendant FRANKLIN JONES.

26. On a second visit to the "church community", on Fiji, which lasted approximately ten days, through March 6, 1984, Plaintiff was to put into the "care of" Defendants PATRICIA TSIKNAS, LYNN CLOSSER, and DOES 90-100, when defendants FRANKLIN JONES and BRIAN O'MAHONY left the community and came to Marin County, California, ostensibly on "church" business. Plaintiff was constantly intimidated, harassed and physically abused until she was able to persuade someone on the island to take her back to the United States.

27. Plaintiff experienced continued physical abuse from Defendant, BRIAN O'MAHONY, until he left her permanently in the later part of June 1984.

28. From approximately 1976 through the latter part of June 1984, Defendants, JOHANNINE DAIST COMMUNION, FRANKLIN JONES, aka DA FREE JOHN, aka BUBBA FREE JOHN, BRIAN O'MAHONY, WILLIAM TSIKNAS, PATRICIA TSIKNAS, LYNN CLOSSER, VINCENT GODDARD, LARRY HASTINGS, JOHN ANDREWS and DOES 1-110, knowingly and willfully conspired and agreed among themselves to deprive Plaintiff of all personal possessions and freedom of movement, as well as to control her mind and will.

29. Defendants herein, through the aforementioned conspiracy, sought to, and did achieve the complete control of Plaintiff by forcing her to accept the tenets and "religious teachings" of Defendant FRANKLIN JONES and the JOHANNINE DAIST COMMUNION. The conspirators comprised of the "followers" of Defendant JOHANNINE DAIST COMMUNION, through duress and harassment were able to compel Plaintiff to give up and surrender to the "Church" all her personal property, including money, forego a promising career as a musician, and persuade Plaintiff to accept severe physical and sexual abuses, and leave her children in the care of the other "followers" for prolonged periods of time. Said conspirators, as a result of additional conspiracies, were responsible for false imprisonment of Plaintiff and for the intentional infliction of emotional distress sustained by said Plaintiff.

30. Defendants, and each of them, did the acts and things herein alleged pursuant to and in furtherance of the conspiracy to maintaining and enriching Defendant JOHANNINE DAIST COMMUNION and its "Master", Defendant FRANKLIN JONES. In addition, the conspiracy sought to enhance the prestige of the "Church" by enlarging its membership by coercive means.

31. Defendants, and each of them, furthered the conspiracy by cooperating with one another to achieve a mutual goal. Said Defendants lent aid and encouragement as well as ratified and adopted the acts of said Defendants, and each of them, in that all acts alleged to have been done by any Defendant were done with the knowledge of all the other Defendants for a specific purpose, i.e., the enrichment and enhancement of Defendant JOHANNINE DAIST COMMUNION, of which all Defendants, including unspecified DOES were members.

32. Defendant, BRIAN O'MAHONY, is, and at all times herein mentioned was, a resident of San Rafael, Marin County, California.

33. Defendant JOHANNINE DAIST COMMUNION is, and at all times herein mentioned was, a Non-Profit Religious Corporation, organized and existing under the laws of the State of California, with its principal office located in San Rafael, County of Marin, California.

34. The various acts, omissions, conspiracies and related activities hereunder alleged, had either their inception or were part of an on-going and continuing process against Plaintiff, which was initiated in the County of Marin, California. The primary location of Defendant JOHANNINE DAIST COMMUNION.

35. Plaintiff was informed and believes, and thereon alleges, that at all times herein mentioned, that each of the Defendants, was the agent of each of the remaining co-Defendants and a member of the JOHANNINE DAIST COMMUNION, and in doing the things hereinafter alleged, was acting within the scope of such agency or membership. Plaintiff further is informed and believes, and thereon alleges, that at all times herein mentioned, each of the Defendants sued herein ad DOE [sic] was the agent of each of the remaining Defendants and a member of the JOHANNINE DAIST COMMUNION, and in doing the things hereinafter alleged, was acting within the scope of such agency or membership.

36. Plaintiff is ignorant of the true names and capacities of Defendants sued herein as DOES 1-110, inclusive, and therefore sues these Defendants by such fictitious names. Plaintiff will amend this Complaint to allege their true names and capacities when obtained. Plaintiff is informed and believes, and thereon alleges, that each of the fictitiously named Defendants is responsible in some manner for the occurrences herein alleged, and that Plaintiff's damages as herein alleged were proximately caused by their conduct.

37. Plaintiff incorporates herein by reference Paragraphs 1-36 as though fully set forth herein.

38. Plaintiff's initial contact with the "religious teachings" of Defendant, FRANKLIN JONES, aka DA FREE JOHN, aka BUBBA FREE JOHN and the JOHANNINE DAIST COMMUNION was the result of loneliness, desperation and the need to find herself. Plaintiff was set upon by several "followers" of Defendant FRANKLIN JONES, named as DOES 1-10, and pulled within their sphere of influence and trust almost immediately.

39. These aforementioned "followers" became an integral part of Plaintiff's life and were able through subtle sophisticated suggestion, trust and coercion to control her every move and thought. The "followers", DOES 1-10, on the urgings and demands of Defendant FRANKLIN JONES, were able to persuade Plaintiff to follow them to the new location of the "Church" on the West Coast, and subsequently become an integral part of their community in Marin County.

40. During the process of taking over Plaintiff's mind and instilling within her the doctrines and "religious teachings" of Defendant FRANKLIN JONES, Defendants JOHANNINE DAIST COMMUNION, BRIAN O'MAHONY, and "followers" DOES 1-10 were able to remove from Plaintiff all her physical possessions, allegedly for the good of Defendant JOHANNINE DAIST COMMUNION and to control Plaintiff's everyday activities, through a combination of mind control, trust, emotional stress and fear.

41. Plaintiff was compelled, over a prolonged period of time, to accept physical and sexual abuses, confinement, degrading acts, inadequate diet, the surrendering of her children over periods of time to "followers", DOES 1-10, and to submit to the demands of Defendants FRANKLIN JONES, BRIAN O'MAHONY and DOES 1-25, without question or hesitancy.

42. Defendants, and each of them gained an unfair advantage by the induced weakness of mind and distress brought about by their prolonged "brainwashing" and physical abuses, and induced Plaintiff to part with personal possessions which were then given to Defendant JOHANNINE DAIST COMMUNION, and to lose all control of any free will or thought process.

43. By an ongoing means of mind control and thought reform, Plaintiff was virtually compelled to do the bidding of Defendants, and each of them, through the latter part of June 1984.

44. But for the undue influence, mind control and thought reformation exerted by defendants, and each of them, on Plaintiff, she would not have exposed herself to the prolonged abuses and to the surrendering of her personal property and free thought.

45. As a proximate result of the facts as herein alleged, Plaintiff was induced to forego a promising musical career, became the victim of severe physical and sexual abuses, and was a virtual captive held under the spell of Defendants for many years. Plaintiff is therefore entitled to punitive damages in the amount of Five Million Dollars ($5,000,000.00)

46. Plaintiff incorporates herein by reference Paragraphs 1-45 as though fully set forth.

47. From 1976 through the latter part of June 1984, Defendant FRANKLIN JONES, through the JOHANNINE DAIST COMMUNION, his agents and "followers", DOES 1-10, falsely and fraudulently by overt and covert statements and actions, represented to Plaintiff that by becoming an active member of the JOHANNINE DAIST COMMUNION and by following the "religious teachings" of their "Master", Defendant FRANKLIN JONES, aka DA FREE JOHN, aka BUBBA FREE JOHN, that Plaintiff would obtain "Spiritual Bliss".

48. The representations made by said Defendants, and each of them, were, in fact, false. The true facts were that the JOHANNINE DAIST COMMUNION was, in fact, an alter-ego of Defendant FRANKLIN JONES, aka DA FREE JOHN, aka BUBBA FREE JOHN, who manipulated Plaintiff by mind control, mind domination, and thought reform, through his various "followers", to surrender to the "Church" her mind, her thought processes and all her worldly belongings.

49. When Defendants made these representations, they knew them to be false, and these representations were made by said Defendants with the intent to defraud and deceive Plaintiff and with the intent to induce Plaintiff to act in the manner herein alleged.

50. Plaintiff, throughout the time these representations were made by said Defendants, and at all times when Plaintiff responded by doing certain acts as herein alleged, was ignorant of the falsity of these representations and believed them to be true. In reliance of these representations, Plaintiff was induced to and did forego all personal belongings, including money; allowed "followers" of the JOHANNINE DAIST COMMUNION and DOES 1-25 to reside in her various homes and residences; allowed herself to be subjected to physical, sexual and mental abuses; became physically and mentally dependent upon Defendants JOHANNINE DAIST COMMUNION, FRANKLIN JONES, BRIAN O'MAHONY, and DOES 1-25; allowed her children to be taken from her and placed in the care of "followers" of the "religion", DOES 26-30; gave up a promising career as a musician as a result of group pressure by DOES 1-10; and, became physically, mentally, and emotionally emaciated as a result of the severe dietary regulations and physical and verbal abuse practiced pursuant to the "religious teachings" of JOHANNINE DAIST COMMUNION, FRANKLIN JONES and DOES 1-5. Had Plaintiff known the actual facts, she would not have taken such action. Plaintiff's reliance on the aforementioned Defendants' representations became justified because Plaintiff was a lonely, naive individual who was set upon by these aforementioned Defendants, who were able to infiltrate her mind and control her thoughts.

51. As a proximate result of the aforementioned Defendants' Fraud and deceit and the facts herein alleged, Plaintiff was induced to forego a promising career as a musician, property and money, and by subtle and controlled mind domination and thought reform lost eight (8) years of her life. As A result of the foregoing, Plaintiff was directly and proximately damaged in an amount which has not yet been determined, and Plaintiff prays leave to amend her Complaint when such amount has been determined.

52. In doing the acts herein alleged, the Defendants, and each of them, acted with oppression, fraud and malice, and therefore Plaintiff is entitled to punitive and exemplary damages in the sum of Five Million Dollars ($5,000,000.00).

53. Plaintiff incorporates herein by reference Paragraphs 1-52 as though fully set forth.

54. From 1976 through the latter part of June 1984, Defendant FRANKLIN JONES, through the JOHANNINE DAIST COMMUNION, his agents and "followers", DOES 1-10, falsely represented to Plaintiff that by becoming an active member of the JOHANNINE DAIST COMMUNION, and by following the "religious teachings" and "doctrines" of their "Master", Defendant FRANKLIN JONES, aka DA FREE JOHN, aka BUBBA FREE JOHN, that Plaintiff would obtain "Spiritual Bliss". Plaintiff was told that the "Master", FRANKLIN JONES, has a "pure birth", one that was "free of karma", and that the "Master" was an "incarnation of God". Plaintiff was told that by accepting the "religious teachings" and "doctrines" of the "Master" and joining the JOHANNINE DAIST COMMUNION, she would "find the way" and become part of a "family" that would always be there for her help and guidance.

Plaintiff, was further told by "followers" that there were "holy obligations" resulting from the "energy generated by the Master" which must be used in order to "prevent negative symptoms being returned to the Master". Everything became dependent upon receiving the "Master's blessing" and once this is received "Spiritual Bliss" becomes a reality.

55. Representations made by said Defendants, and each of them, were, in fact, false. The true facts were that Plaintiff had become a victim of brainwashing, as a result of her subtle and gradual isolation from society, and the manipulation of her environment. She was systematically debilitated through inadequate diet, degradation, and diminution of herself. Peer pressure was applied to general guilt and monotonous tasks were assigned in furtherance of Plaintiff's indoctrination into the JOHANNINE DAIST COMMUNION.

56. Defendants, "followers" of the "Master", DOES 1-100, made the aforementioned representations with no reasonable grounds for believing them to be true. Plaintiff is informed and believes that Defendants, and each of them, did not have any information, upon which to believe or reasonably come to any conclusion concerning the alleged "pure birth of the Master", or that he was an "incarnation of God". These, as well as other statements were made by Defendants, and each of them, to persuade Plaintiff that the JOHANNINE DAIST COMMUNION and the "Master", Defendant FRANKLIN JONES, should become a way of life for her. Defendants, and each of them, were aware that they had no information to accurately make the representations herein alleged, but continued to make these and other representations to Plaintiff, continually concealing from her that they lacked adequate background information relating to said representations.

57. These representations were made by Defendants, and each of them, with the intent to induce Plaintiff to act in the manner herein alleged.

58. Plaintiff, at the time these representations were made by defendants, and each of them, and at the time Plaintiff took the actions herein alleged, was ignorant of the falsity of said Defendants' representations, and believed them to be true. In reliance on these representations, Plaintiff was induced to, and did join the JOHANNINE DAIST COMMUNION, and became one of the members of the "Church". In addition, Plaintiff surrendered her personal belongings and allowed herself to become subject to physical, mental and sexual abuses. She became physically and mentally dependent upon Defendants JOHANNINE DAIST COMMUNION, FRANKLIN JONES, BRIAN O'MAHONY, and DOES 1-100. Plaintiff withdrew from the "outside" world, and became a member of the closed cult environment, abandoning a promising profession as a musician and removing herself from any individuals who were not "followers" of the JOHANNINE DAIST COMMUNION. Had Plaintiff known the actual facts, she would not have taken such action. Plaintiff's reliance on said Defendant's representations was justified because Plaintiff had become a victim of coercive persuasion as a result of trying to find herself. Plaintiff was lonely and susceptible to the suggestive "ideological" remodeling, and was susceptible to the indoctrination of the "religious teachings" of the "Master", subtly imposed upon her by the "followers" of the JOHANNINE DAIST COMMUNION.

59. As a proximate result of the aforementioned Defendants' deceit and the facts herein alleged, Plaintiff was induced to forego a career as a promising musician, was deprived of her property and money, and by subtle and controlled mind domination and thought reform, lost eight (8) years of her life. As a result of the foregoing, Plaintiff was directly and proximately damaged in an amount which has not yet been ascertained, and Plaintiff prays leave to amend her Complaint when such amount has been determined, or according to proof at trial.

60. In doing the acts herein alleged, Defendants, and each of them, acted with oppression, fraud and malice, and therefore, Plaintiff is entitled to punitive and exemplary damages in the sum of Five Million Dollars ($5,000,000.00).

61. Plaintiff incorporates herein by reference Paragraphs 1-60 as though fully set forth.

62. At all times herein mentioned, Defendants, and each of them, were fully aware of Plaintiff's susceptibility to emotional distress as they had full knowledge of the mental condition of said plaintiff, which resulted from the control and domination over Plaintiff.

63. For approximately and eight (8) year period, Plaintiff was under the physical and mental control of Defendants JOHANNINE DAIST COMMUNION, FRANKLIN JONES, BRIAN O'MAHONY and DOES 1-50. As such, Plaintiff was compelled through coercive means to accept physical and sexual abuse and to follow all orders from those Defendants who were in authority pursuant to the structure of Defendant JOHANNINE DAIST COMMUNION. Plaintiff was under the constant surveillance and supervision of all named Defendants and DOES 1-100, "followers" of the "teachings" of Defendant JOHANNINE DAIST COMMUNION, resulting in a complete submission to the demands, requests and suggestions of the aforementioned Defendants. Over the years, Plaintiff was made the object of scorn and ridicule by Defendants, and each of them, for a variety of "offenses", consisting of, but not limited to, not following the dietary laws as espoused by Defendant, FRANKLIN JONES, for not wishing to spend all her time with fellow members of Defendant, JOHANNINE DAIST COMMUNION, and for her physical appearance.

64. The conduct of Defendants, and each of them, was intentional and malicious, and done for the purpose of causing Plaintiff to suffer humiliation, mental anguish and emotional and physical distress. The conduct of Defendants, and each of them, in confirming and ratifying that conduct was done with the knowledge that Plaintiff's emotional and physical distress would thereby increase, signifies that said conduct was done with a wanton and reckless disregard of the consequences to Plaintiff.

65. As a proximate result of the aforementioned acts, Plaintiff suffered humiliation, mental anguish, and emotional and physical distress and has been injured in mind and body as follows:

Physically, Plaintiff, as a result of prolonged beatings sustained broken bones, contusions and abrasions. Mentally, as a result of Defendants' ability to brainwash, Plaintiff suffered from great emotional distress, all to Plaintiff's damages in the sum of Five Million Dollars ($5,000,000.00).

66. By reason of the aforementioned acts, Plaintiff was prevented from pursuing her profession as a musician, and thereby lost earnings in an amount not yet ascertained, and Plaintiff prays leave to amend her Complaint when such amount has been determined. Plaintiff is informed and believes, and thereon alleges, that she will be prevented from attending to her usual profession for a period in the future which cannot be ascertained, and will thereby sustain further loss of earnings.

67. In doing the acts herein alleged, Defendants, and each of them, acted with oppression, fraud and malice, and therefore, Plaintiff is entitled to punitive and exemplary damages in the sum of Five Million Dollars ($5,000,000.00).

68. Plaintiff incorporates herein by reference Paragraphs 1-52 as though fully set forth.

69. At all times herein mentioned Defendants, and each of them, either were aware or should have been fully aware that Plaintiff was susceptible to emotional distress as said Defendants, and each of them, had full knowledge of the mental conditions of Plaintiff, and of the domination and control exerted over Plaintiff by Defendants FRANKLIN JONES, BRIAN O'MAHONY, the JOHANNINE DAIST COMMUNION, and DOES 1-100.

70. For approximately an eight (8) year period, Plaintiff was under the physical and mental control of Defendants FRANKLIN JONES, JOHANNINE DAIST COMMUNION, BRIAN O'MAHONY and DOES 1-50. As such Plaintiff was compelled through coercive means to accept physical, mental and sexual abuse and to follow all orders from those Defendants who were in authority pursuant to the structure of Defendant JOHANNINE DAIST COMMUNION. Plaintiff was under the constant surveillance and supervision of all named Defendants and DOES 1-100, "followers" of the "teachings" of Defendant JOHANNINE DAIST COMMUNION, resulting in a complete submission to the demands, requests and suggestions of the aforementioned Defendants. Over the years, Plaintiff was made the object of scorn and ridicule by Defendants, and each of them, for a variety of "offenses", consisting of, but not limited to, not following the dietary laws as espoused by Defendant, FRANKLIN JONES, for not wishing to spend all her time with fellow members of Defendant, JOHANNINE DAIST COMMUNION, and for her physical appearance.

71. The conduct of Defendants, and each of them, was so grossly careless and negligent that resulting humiliation, mental anguish, and emotional and mental distress could have been expected and was foreseeable.

72. The conduct of Defendants, and each of them, in confirming and ratifying the negligent and careless conduct resulted in foreseeable emotional and physical distress experienced by Plaintiff.

73. By reason of the aforementioned acts, Plaintiff was prevented from pursuing her profession as a musician, and thereby lost earnings in an amount which has not yet been ascertained, and Plaintiff prays leave to amend her Complaint when such amount has been determined, or according to proof at trial. Plaintiff is informed and believes, and thereon alleges, that she will be prevented from attending to her usual profession for a period in the future which cannot be ascertained, and will thereby sustain further loss of earnings.

74. As a proximate result of this negligence and carelessness by Defendants, and each of them, Plaintiff suffered prolonged shock to her nervous system and sustained repeated physical abuses resulting in several broken bones and multiple abrasions and. contusions, all to her damage in the sum of Five Million Dollars ($5,000,000.00).

75. Plaintiff incorporates herein by reference Paragraphs 1-45 as though fully set forth.

76. During the latter part of February 1984, and through March 6, 1984, Defendants FRANKLIN JONES, BRIAN O'MAHONY, WILLIAM TSIKNAS, PATRICIA TSIKNAS, LYNN CLOSSER, and DOES 50-60, and each of them, formed a common plan and scheme to unlawfully hold and imprison Plaintiff, and did, in fact, pursuant to the operation of said plan and scheme, unlawfully hold Plaintiff against her will without her consent and over her protest. Plaintiff had gone to a community run by Defendant JOHANNINE DAIST COMMUNION with Defendant BRIAN O'MAHONY, ostensibly on "Church" business.

77. After arriving at the "Church" community, which is located on Translation Island in Fiji, pursuant to the common plan or scheme to falsely imprison Plaintiff, Defendants FRANKLIN JONES and BRIAN O'MAHONY left Plaintiff on the island "in the care of" certain women "followers" of the "Church", DOES 50-60, and came to San Rafael, County of Marin, California, in furtherance of said common plan and scheme, and Defendants FRANKLIN JONES and BRIAN O'MAHONY, and each of them, while in San Rafael,, California, continued to operate, control, dominate, and further design and commit the furtherance of said plan and scheme, and did ratify and adopt it for their mutual benefit, and for the benefit of each of them, and for the benefit of Defendant, JOHANNINE DAIST COMMUNION.

78. For a period of approximately eight (8) days, Plaintiff was a prisoner on the island, as there were no means whatsoever by which Plaintiff could escape, although she repeatedly requested to do so. Plaintiff was under the full control and custody of the aforementioned Defendants, and each of them, and was held against her will by the use of threats, coercion, and the remoteness of the location where she was held.

79. Plaintiff, after eight (8) days of captivity, was finally able to locate someone who was leaving the island and agreed to take her with him. She was able to persuade her captors to release her from the forced imprisonment.

80. Immediately prior to the acts of Defendants as herein alleged, Plaintiff was residing within the JOHANNINE DAIST COMMUNION community with Defendant, BRIAN O'MAHONY, and committed no act which would give Defendants, and each of them, reason to hold Plaintiff against her will.

81. Defendants, and each of them, by making the threats and acting in a menacing manner resulting in the imprisonment of Plaintiff, acted with deliberate malice for the sole purpose of keeping Plaintiff within their control and the control of Defendants JOHANNINE DAIST COMMUNION and FRANKLIN JONES.

82. As a proximate result of the acts of Defendants, and each of them, Plaintiff was injured in her health, strength and activity, sustaining injuries to her body and shock and injury to' her nervous system and person, all of which injuries have caused Plaintiff to suffer extreme and severe physical pain and mental anguish. These injuries will result in some permanent disability to Plaintiff, all to her general damage in an amount which has not yet been ascertained, and Plaintiff prays leave to amend her Complaint when such amount has been determined, or according to proof at trial.

83. The acts of Defendants, and each of them, as herein alleged, were willful, wanton, malicious and oppressive, and justify the awarding of punitive and exemplary damages in the amount of Five Million Dollars ($5,000,000.00).

84. Plaintiff is, and at all times herein mentioned, a resident of Marin County, California.

85. Defendant, JOHANNINE DAIST COMMUNION, is, and at all times herein mentioned, was a Non-Profit Religious Corporation organized and existing under the laws of the State of California, with its principal office located in Marin County, California.

86. Defendant, FRANKLIN JONES, aka DA FREE JOHN, aka BUBBA FREE JOHN, is, and at all times herein mentioned, was the leader of Defendant, JOHANNINE DAIST COMMUNION, and as such, with or without shares in said corporation, controlled, determined and dictated each and every act carried out by Defendant JOHANNINE DAIST COMMUNION.

87. There exists, and at all times herein mentioned existed, a unity of interest and ownership between Defendants JOHANNINE DAIST COMMUNION and FRANKLIN JONES, aka DA FREE JOHN, aka BUBBA FREE JOHN, such that there has never been individuality and separateness between said Defendants. Defendant, FRANKLIN JONES, aka DA FREE JOHN, aka BUBBA FREE JOHN, in collusion and concert with Defendants BRIAN O'MAHONY, WILLIAM TSIKNAS, PATRICIA TSIKNAS, LYNN CLOSSER and DOES 60-70, completely controlled, dominated, managed and operated Defendant JOHANNINE DAIST COMMUNION, and used assets of the corporation for his personal uses, caused assets of the corporation to be transferred to him without adequate consideration, and used corporate funds for his personal use. Defendant, FRANKLIN JONES provided luxurious accommodations, food and clothes for himself, his wives, and his children, while directing his "followers" to live very austere lives of poverty.

88. Adherence to the fiction of the separate existence of the Defendant corporation as an entity distinct from Defendant FRANKLIN JONES, would permit an abuse of the corporate privilege, and would sanction fraud, in that Defendant, FRANKLIN JONES, caused vast sums of money to be withdrawn from the funds of Defendant, JOHANNINE DAIST COMMUNION, and distributed to himself without any consideration to Defendant JOHANNINE DAIST COMMUNION, all for the purpose of his personal and general use. In addition, an injustice will result if the theoretical entity of the corporate Defendant is not disregarded and Defendant, FRANKLIN JONES, held personally liable and accountable for his actions.

89. The Defendant corporation was, and is, a mere sham and shell organized as the alter-ego of the individual Defendant, FRANKLIN JONES, for his personal benefit and advantage.

90. Plaintiff incorporates herein by reference Paragraphs 1-45 as though fully set forth.

91. During the early part of March 1984, Defendants WILLIAM TSIKNAS, PATRICIA TSIKNAS, LYNN CLOSSER, and DOES 50-60, assaulted, Plaintiff by threatening great bodily harm if she tried to escape from within their area of control. Defendants, and each of them, by their threats and prior actions of beating women who had disobeyed the tenets and "religious teachings" of Defendants, FRANKLIN JONES and JOHANNINE DAIST COMMUNION, placed Plaintiff in great fear of her life and physical well-being.

92. By reason of the wrongful and malicious acts of Defendants and each of them, and of the fright caused Plaintiff, Plaintiff has suffered extreme and severe mental anguish and physical pain, and has been injured in mind and body, all to Plaintiff's damage in an amount that has not been ascertained, and Plaintiff prays leave to amend her Complaint when such amount has been determined, or according to proof at trial.

93. The aforementioned acts of Defendants, and each of them were willful, wanton, malicious and oppressive, and justify the awarding of punitive and exemplary damages in the amount of Five Million Dollars ($5,000,000.00).

94. Plaintiff incorporates herein by reference Paragraphs 1-45 as though fully set forth.

95. From early March 1984 through early June 1984, Defendant BRIAN O'MAHONY assaulted and battered Plaintiff by persistent threats to strike her and, in fact, did violently strike Plaintiff many times over a prolonged period of time, concluding in June 1984. Said Defendant struck Plaintiff on numerous occasions about her body and face, and more specifically on her ear.

96. By reason of the acts of Defendant BRIAN O'MAHONY, as aforementioned, Plaintiff was placed in great fear of her life and physical well-being.

97. By reason of the wrongful and malicious acts of Defendant BRIAN O'MAHONY and the fright caused Plaintiff, Plaintiff has suffered extreme and severe mental anguish and has been injured in mind and body, all to Plaintiff's damage in an amount that has not been ascertained, and Plaintiff prays leave to amend her Complaint when such amount has been determined, or according to proof at trial.

98. By reason of the wrongful and malicious acts of Defendant BRIAN O'MAHONY, Plaintiff was required to and did expend monies, and incurred obligations for medical services, drugs and sundries reasonably required in the treatment of the emotional disturbance and physical injuries she sustained. The exact amount of these medical expenses is not now known to Plaintiff, and when the same have been ascertained, Plaintiff will request permission to amend this Complaint so as to set forth the various items and the total of such charges and expenses.

99. The aforementioned acts of Defendant BRIAN O'MAHONY were willful, wanton, malicious and oppressive, and justify the awarding of punitive and exemplary damages in the amount of Five Million Dollars ($5,000,000.00).

100. Plaintiff incorporates herein by reference Paragraphs 1-36, as though fully set forth.

101. At all times herein mentioned, VINCENT GODDARD, BRIAN O'MAHONY, LARRY HASTINGS, JOHN ANDREWS and DOES 60-70 were directors of Defendant, a Non-Profit Religious Corporation, JOHANNINE DAIST COMMUNION.

102. Within the last three (3) years, the aforementioned directors, and each of them, were directly responsible for appointing and overseeing the leadership of the Defendant, JOHANNINE DAIST COMMUNION. Said directors, with full knowledge of misconduct and abuse, repeatedly reaffirmed the actions of Defendant, FRANKLIN JONES, in his capacity as the "spiritual leader" of Defendant JOHANNINE DAIST COMMUNION.

103. The directors, and each of them, were fully aware that various members of Defendant JOHANNINE DAIST COMMUNION were physically and sexually abused, forced into a position of involuntary servitude, falsely imprisoned by a form of "house arrest", and were the recipients of constant verbal abuse and duress.

104. The directors, and each of them, were fully aware that Defendant FRANKLIN JONES, diverted funds from Defendant, JOHANNINE DAIST COMMUNION, for his own personal use, and that Defendant FRANKLIN JONES ratified and condoned this action.

105. In acting as hereinabove described, Defendants, and each of them, did not exercise the care required by directors, in that with full knowledge they allowed continuing criminal acts to take place within the Defendant JOHANNINE DAIST COMMUNION, and allowed the "followers" of the Defendant, JOHANNINE DAIST COMMUNION, to be subjected to continued abuses, assaults, duress, coercion, degradation, and humiliation. Said directors, and each of them, had a duty and obligation to protect the "followers" from the aforementioned abuses; however, rather than stopping the aforementioned activities, the directors, and each of them, sanctioned and ratified these abuses and acts.

106. As a proximate result of the malfeasance and misfeasance of the directors, and each of them, hereinabove described, Plaintiff has been damaged in an amount not yet ascertained, and Plaintiff prays leave to amend her Complaint when such amount has been determined, or according to proof at trial.

107. Plaintiff incorporates herein by reference Paragraphs 1-45 as though fully set forth.

108. At all times herein mentioned, Defendant FRANKLIN JONES, publicly held himself out as the spiritual leader of Defendant JOHANNINE DAIST COMMUNION, under the names of DA FREE JOHN and BUBBA FREE JOHN.

109. Said Defendant has written numerous books and articles describing how one may obtain "Spiritual Bliss". These writings are directed at people seeking a new awareness or enlightenment, and geared to initiate an indoctrination into Defendant JOHANNINE DAIST COMMUNION. This literature and the "followers" of Defendant, JOHANNINE DAIST COMMUNION, are all under the control and direction of defendant, FRANKLIN JONES.

110. once initial interest has been shown by a party attracted to the alleged "religious teachings" of Defendant, FRANKLIN JONES, the trap is sprung and ideological remodeling or thought reform begins to take place. The new "follower" is basically isolated from his or her environment and all manners of communication are controlled by Defendant FRANKLIN JONES, under the guise of his leadership of the JOHANNINE DAIST COMMUNION. As part of the indoctrination, the stimulation of uncertainty, fear and confusion is gradually applied with certain rewards being given for surrendering oneself to the group. Peer pressure is applied, resulting in extreme feelings of guilt. In conjunction with the aforementioned, monotonous tasks and repetitive activities are required.

111. Defendant, FRANKLIN JONES, is fully aware that the purpose of the aforementioned acts are to brainwash potential "followers" and relieve them of any self defenses they may have with regard to said Defendant's wishes and demands. As punishment for not behaving as set forth by the "Master" (Defendant, FRANKLIN JONES), "followers" are publicly denounced within the "Church" or are shunned by members of the congregation.

112. Defendant, FRANKLIN JONES, in his position as leader of the JOHANNINE DAIST COMMUNION, has on numerous occasions demanded that his "followers" commit deviant sexual acts, administer beatings or apply a form of "house arrest" to other "followers" who have deviated from the path as set forth by said Defendant.

113. Plaintiff, after undergoing a period of subtle brain-washing, under the direction and command of Defendant FRANKLIN JONES, became a "follower" of the JOHANNINE DAIST COMMUNION. During a prolonged period, Plaintiff became a victim of the aforementioned sexual abuses, beatings and "house arrest", and accepted such "punishments" for fear of being ridiculed or shunned by fellow "followers of the "Master".

114. Within the last year, Plaintiff was able to break the mental and psychological bounds that held her to the JOHANNINE DAIST COMMUNION, finally realizing that the initial "religious teachings" and "doctrines" espoused by Defendant FRANKLIN JONES, were a sham and a travesty, and that Defendant, FRANKLIN JONES, was only concerned with having as many obedient "followers" under his control as possible.

115. The conduct of Defendant, FRANKLIN JONES, was in wanton disregard for the rights and well-being of Plaintiff, and was intentional and malicious, done for the purpose of causing Plaintiff to lose her free will and to suffer humiliation and mental anguish.

116. Defendant, FRANKLIN JONES, as a spiritual leader of Defendant, JOHANNINE DAIST COMMUNION, was solely concerned with the power he exerted over Plaintiff and other "followers", and the "doctrines" and "religious teachings" that were contained within his sermons and writings were a meaningless sham known by said Defendant to be untrue, confusing, misleading and hypnotic. Said Defendant's outrageous conduct was done with the knowledge that Plaintiff would become more physically and emotionally bound to the JOHANNINE DAIST COMMUNION, and was done with a wanton and reckless regard to the consequences to Plaintiff.

117. As a proximate result of the acts of Defendants, and each of them, Plaintiff was inured in her health, strength and activity, sustaining injuries to her body and shock and injury to her nervous system and person, all of which injuries have caused Plaintiff to suffer extreme and severe physical pain and mental anguish. These injuries will result in some permanent disability to Plaintiff, all to her general damage in an amount which has not yet been ascertained, and Plaintiff prays leave to amend her Complaint when such amount has been determined, or according to proof at trial.

118. All of the aforementioned acts of Defendant, FRANKLIN JONES, were willful, wanton malicious, and oppressive, and justify the awarding of punitive and exemplary damages in the amount of Five Million Dollars ($5,000,000.00)

119. Plaintiff incorporates herein by reference Paragraphs 1-74 as though fully set forth.

120. Defendants, JOHANNINE DAIST COMMUNION, FRANKLIN JONES, and DOES 1-100, were fully aware at all times herein mentioned, that Plaintiff's indoctrination into the JOHANNINE DAIST COMMUNION consisted of relinquishing her free will and becoming an automaton, subject of the commands and desires of the "Master", Defendant FRANKLIN JONES. In such a capacity, Plaintiff was compelled to work and perform services for the JOHANNINE DAIST COMMUNION without pay or remuneration of any kind whatsoever for a period of approximately eight (8) years.

121. The aforementioned labor performed for the Defendant, JOHANNINE DAIST COMMUNION, at the command of Defendant FRANKLIN JONES, amounted to involuntary servitude in which several thousand hours of work product was received by Defendant, JOHANNINE DAIST COMMUNION. Plaintiff should be reimbursed pursuant to the theory quantum meruit in an amount not yet ascertained, and Plaintiff prays leave to amend her Complaint when such amount has been determined or according to proof at trial.

122. As a proximate result of the acts of Defendants, and each of them, Plaintiff was injured in her health, strength and activity, sustaining injuries to her body and shock and injury to her nervous system and person, all of which injuries have caused Plaintiff to suffer extreme and severe physical pain and mental anguish. These injuries will result in some permanent Disability to Plaintiff, all to her general damage in an amount which has not yet been ascertained, and Plaintiff prays leave to amend her Complaint when such amount has been determined, or according to proof at trial.

123. The acts of Defendants, and each of them, as herein alleged, were willful, wanton, malicious and oppressive, and justify the awarding of punitive and exemplary damages in the amount of Five Million Dollars ($5,000,000.00).

WHEREFORE, Plaintiff prays for judgment against Defendants, and each of them as follows:

FIRST, SECOND, THIRD, FOURTH, FIFTH, SIXTH, EIGHTH, NINTH, ELEVENTH AND TWELFTH CAUSES OF ACTION:

1. For damages according to proof,

2. For punitive and exemplary damages in the amount of Five Million Dollars ($5,000,000.00)

3. For such other and further relief as the Court deems appropriate.

SEVENTH AND TENTH CAUSES OF ACTION:

1. For damages according to proof.

2. For such other and further relief as the Court deems appropriate.

Dated: March 4, 1985

[signed]
DAVID L. CUNNINGHAM Attorney for
Plaintiff BEVERLY JACOBS O'MAHONY

STATE OF CALIFORNIA,
COUNTY OF MARIN

I, the undersigned, say; I am the Plaintiff in the above entitled action; I have read the foregoing COMPLAINT FOR DAMAGES: UNDUE INFLUENCE; INTENTIONAL MISREPRESENTATION; FRAUD; DECEIT; NEGLIGENT MISREPRESENTATION; INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS; FALSE IMPRISONMENT: CORPORATION ALTER EGO OF FRANKLIN JONES; ASSAULT: ASSAULT AND BATTERY; BREACH OF DIRECTOR'S DUTY; MALPRACTICE OF CLERGY; and INVOLUNTARY SERVITUDE, and know the contents thereof; and that the same is true of my own knowledge, except as to the matters which are therein stated upon my information or belief, and as to those matters that I believe it to be true.

I declare under penalty of perjury, that the foregoing is true and correct.

Executed on March 4, 1985 at Sausalito, Marin County, California

[signed]
BEVERLY JACOBS O'MAHONY,
Plaintiff

BEVERLY JACOBS O'MAHONY,