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WARNER & JACKSON
639 South Spring Street
Los Angeles 14, California
Attorneys for Plaintiff
[Stamped: FILED Apr 23, 1951, Harold Cecily, County Clerk]
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF LOS ANGELES
SARA NORTHRUP HUBBARD,
L. RON HUBBARD, also known as LAFAYETTE RONALD HUBBARD; Los Angeles Department HUBBARD DIANETIC RESEARCH FOUNDATION, a partnership; THE HUBBARD DIANETIC RESEARCH FOUNDATION OF CALIFORNIA, INC., a California corporation; FRANK B.DESSLER; RICHARD B. DE MILLE; VINCE MC GONIGEL; WESTWOOD NURSES REGISTRY AGENCY; BEKINS VAN AND STORAGE CO.; BANK OF AMERICA NATIONAL TRUST & SAVINGS ASSOCIATION; SECURITY FIRST NATIONAL BANK OF LOS ANGELES; DOE ONE, DOE TWO, DOE THREE, DOE FOUR,DOE FIVE, DOE SIX, DOE SEVEN, DOE EIGHT, DOE NINE and DOE TEN,
COMPLAINT FOR DIVORCE
COMES NOW the plaintiff and for cause of action against defendants alleges and says:
That in the early part of 1946, plaintiff, then age 21 and unmarried, resided with her family in Pasadena, and a the University of Southern California, that at said time, defendant L. Ron Hubbard, hereinafter referred to as “Hubbard”, was a married man, age 35, he being then married to Margaret Grubb
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Hubbard of Bremerton, Washington, they having two children; that said Hubbard represented to plaintiff that he was single and unmarried, and plaintiff relying upon said representation, and having fallen in love, entered into a marriage ceremony with said Hubbard on the 10th day of August, 1946, at Chestertown, Maryland that said Hubbard thereafter secured a divorce from said Margaret Grubb Hubbard on or about the 24th day of December, 1947, at Port Orchard, Washington; that plaintiff and said Hubbard ever since the said 10th day of August, 1946, have lived together as husband and wife, and on the 8th day of March, 1950, had a child born to them, Alexis Valorie [sic] Hubbard, at Point Pleasant, New Jersey; that the parties have always considered themselves husband and wife in their travels about the nation; that at all times herein mentioned, said Hubbard has represented to plaintiff that they were legally married, and plaintiff relied upon such representations; that by reason thereof, plaintiff alleges herein. that plaintiff and said Hubbard are husband and wife; that in the event it should be held that the parties are not legally married, plaintiff will seek the damages prayed for herein for fraud and deceit on the part of said Hubbard, in entrapping plaintiff into the matrimonial predicament that she now finds herself in.
That plaintiff was born in Pasadena, California on the 8th day of April, 1925, and grew up and was educated in the State of California; that plaintiff does now and always has considered California to be her home state, and plaintiff and said Hubbard have maintained their residence in California from time to time since said marriage in between their travels about the United States and at all times have had their furniture in the State of California, and have considered California to be their permanent residence; that by reason thereof, plaintiff is now and for more
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than one year immediately preceding the commencement of this action, has been a resident of the State of California; that plaintiff has been a resident of the County of Los Angeles for more than three months, immediately preceding the commencement of this action.
Statistical facts required by section 426a of the Civil Code of Procedure are:
Place of marriage; Chestertown, Maryland;
Date of marriage; On the 10th day of August 1946;
Date of separation; On or about the 24th day of February 1951;
Time elapsing between the date of marriage and the date of separation; Approximately four years, six months and twelve days; and there is one child of the marriage; Alexis Valorie Hubbard, age 13 months.
That there is community property of the plaintiff and said Hubbard consisting of a community interest in the Hubbard Dianetic Research Foundation, with its headquarters in Elizabeth. New Jersey, and which operates a school and clinic in Chicago, Illinois, New York City, Los Angeles, Honolulu, Wichita, Kansas, and elsewhere; that said Hubbard and said foundation did over one million dollars in business during the year 1950, and owns valuable community property and assets; that said foundation operates in the State of California, under the name of “The Hubbard Dianetic Research Foundation of California, Inc., a California corporation”, defendant herein; that said corporation. is the alter ego of said Hubbard.
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That said separation took place by reason of the extreme cruelty practiced upon the plaintiff by the said Hubbard, which has caused the plaintiff great mental anguish and physical suffering during the past five years of the married life of the parties, consisting in part as follows;
That during the marriage up until the month of October, 1950, said Hubbard, an “older man” completely dominated the youthful plaintiff, both physically, mentally and emotionally and taking advantage of her trusting love and desire for a successful marriage, repeatedly subjected plaintiff to systematic torture, including loss of sleep, beatings, and strangulations and scientific torture experiments, including the following:
That in the latter part of September, 1950, said Hubbard told plaintiff at the Chateau Marmont Apartments in Hollywood, that “I do not want to be an American husband for I can buy my friends whenever I want them”, and he further said that he, Hubbard, did not want to be married, yet divorce was impossible, for a divorce would hurt his reputation, and that she, plaintiff, should kill herself if she really loved him. That at said time and place, said Hubbard systematically prevented plaintiff from sleeping continuously for a period of over four days, and then in her agony, furnished her with a supply of sleeping pills, all resulting in a nearness to the shadow of death. That the foregoing was a frequent occurence [sic] during the married life of the parties. That at said time and place, plaintiff became numb and lost consciousness, and was thereafter taken by said Hubbard to the Hollywood Leland Hospital, where she was kept under a vigilant guard from friend and family under an assumed name, for five days. That shortly following Christmas, 1953, said Hubbard
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violently strangled plaintiff and sadistically ruptured the eustachian tube of her left ear, resulting in the impairment of her hearing. That such strangulation of plaintiff was a frequent practice on the part of said Hubbard.
That in January, 1951, at Palm Springs, while plaintiff was getting out of an automobile operated by said Hubbard he intentionally started the said car in gear, thus propelling plaintiff to the pavement resulting in serious personal injury.
That plaintiff and her medical advisors, following the foregoing incidents, concluded that said Hubbard was hopelessly insane, and crazy, and that there was no present hope for said Hubbard, or any reason for her to indure [sic] further; that competent medical advisors recommended that said Hubbard be committed to a private sanitarium for psychiatric observation and treatment of a mental ailment known as paranoid schizophrenia; that plaintiff, on the 23rd day of February, 1951, caused the national executive officer of the Hubbard Dianetic Research Foundation at Elizabeth, New Jersey, to be advised of said preliminary diagnosis and urgent need for treatment; that said national officer immediately advised said Hubbard of said diagnosis.
That at 11;00 o’clock P.M., on said 23rd day of February, 1951, said Hubbard, together with defendant Frank B. Dessler, head of the Los Angeles Dianetic Foundation, abducted the infant child of the parties, Alexis from her crib, and deposited said infant in West Los Angeles with defendant Vince Mc Gonigle under the assumed name of Anne Marie Olson, and concealed said infant from plaintiff until this day. That this was admitted by said Dessler in the habeas corpus proceedings filed on the 10th day of April, 1951 entitled In re Alexis Valorie Hubbard, Los Angeles Superior Court Number H.C. 35879.
That said Hubbard, Dessler and defendant Richard B. De Mille, having secreted said infant child, feloniously dragged
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plaintiff out of her bed attired only in her night gown, it then being 1;00 o’clock A.M., of the morning of the 24th day of February, 1951, and by the use of threats, strangulation, torture, and false promises to return her child to her, carried and kidnapped plaintiff to Yuma, Arizona, all as is detailed at length in the habeas corpus proceeding above mentioned.
That plaintiff has ever since sought the whereabouts of her infant child, and has consulted attorneys, police, sheriffs, Federal Bureau Of Investigation agents, and courts, and has brought said habeas corpus proceedings; that said Hubbard and his attorneys refuse any information as to the whereabouts of her infant child, unless she goes back to live with said Hubbard, an alternative that means certain continued torture and possible death, a predicament no good woman, wife and mother should have to face.
That through all her trials and tribulations, and up until the month of February, 1951, plaintiff bore her suffering and sorrows in silence and even now would not bare the truth to the world, except for the compelling advice of her attorney, Caryl Warner, that she tell the truth for the truth will make her free, and the truth alone, will bring back her baby, if alive.
That by reason of the foregoing crazy misconduct of said Hubbard, plaintiff is in hourly fear of both the life of herself and of her infant daughter, who she has not seen for two months. That all of said acts on the part of said Hubbard towards the plaintiff have been without cause or justification, and without the consent of the plaintiff, and have caused her great mental anguish and horrible physical suffering.
That the custody of said infant child Alexis should be awarded to plaintiff, without reservation or condition; that the Court should order and compel said Hubbard to submit to legitimate
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psychiatric examination in the interests of tile welfare and safety of said minor child, who is secreted by Hubbard someplace in North America.
That said Hubbard is an able-bodied man, and is well able to support and provide for plaintiff and their child; that by reason thereof, said Hubbard should be ordered to pay to plaintiff reasonable support for plaintiff and said infant child during the pendency of this action, and thereafter pay permanent alimony and child support; that in addition thereto, said Hubbard should be ordered to pay a reasonable sum as and for attorney’s fees and costs of suit; that a lien should be impressed upon the real property hereinafter described to secure payment of the sums allowed herein.
That said Hubbard has harrassed [sic], injured and kidnapped plaintiff as alleged herein, and has threatened to kill plaintiff; that plaintiff is informed and believes, and upon such information and belief alleges that said Hubbard, unless restrained from so doing, will carry out his said threats, and will again injure and molest plaintiff; that by reason thereof, the Court should restrain said Hubbard from molesting or injuring plaintiff during the pendency of this hearing of this cause, and upon the trial of this action, the Court should permanently enjoin said Hubbard from committing any of said acts in regard to plaintiff.
That said Hubbard departed from the State of California on the 24th day of February, 1951, and ever since has remained outside of California, for the purpose of evading the process of the Court, and for the purpose of attempting to deprive plaintiff of her marital rights herein; that said absence from the State on the part of said Hubbard was and is for the purpose of resisting
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plaintiff’s efforts to enforce her said rights against said defendant for support and maintenance for herself and her child and to obtain an equitable division of the community property of the parties; that said Hubbard has repeatedly threatened that he would stay out of California so as to make it impossible for her to get any money or support from him and to prevent her from sharing in the community property of the parties, and said Hubbard has stated that he would do everything in his power to deprive plaintiff. of all of her said marital rights; that plaintiff is informed and believes, and upon such information and belief, alleges that pursuant to said threats, said Hubbard has concealed various community assets, and has placed said assets in the name of Hubbard Dianetics Research Foundation, and in the names of the other defendants named herein, and in the names of other persons unknown to the plaintiff that said Hubbard will continue to further hide and conceal said community property assets from plaintiff unless prevented from doing so by the appointment of a receiver herein; that by reason of the said acts of said Hubbard, plaintiff has been compelled to exhaust her own personal estates and to draw upon her family for support; that by reason thereof, plaintiff is without adequate funds for her own support or the support of her child, or to prosecute this action; that all of the acts heretofore set forth on the part of said Hubbard were perpetrated intentionally and willfully and for the express purpose of defrauding plaintiff of her said marital rights, and to unjustly and fraudulently deprive plaintiff of any and all of her rights whatsoever, and to render her helpless and subject to his complete and arbitrary will and domination.
That said receiver should be empowered to take over, operate, and sell the defendant Hubbard Dianetic Research Foundation of California, Inc., property at 2300 South Hoover Street, Los
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Angeles, California, and more particularly described as; Lot 6 of Belgravia Tract, in the City of Los Angeles, County of Los Angeles, State of California, 8S per map in Book 23, Page 54 of Miscellaneous Records of said County, and a portion of Lot 3, Block 22, of Hancock’s Survey in said City and County of Los Angeles, as per map recorded in Book 2, page 108 of Miscellaneous Records of said county; that said receiver should be allowed to pay to plaintiff such sums as the Court may allow for the support of plaintiff and the minor child, and for her attorney’s fees and costs incurred herein; that plaintiff has no plain, speedy or adequate remedy at law other then the appointment Of a receiver, for the reasons set forth herein.
That the true names or capacities, whether individual corporate, associate or otherwise, of defendants Doe One through Doe Tens inclusive, are unknown to plaintiffs who there ore sues said defendants by such fictitious names, and will as, leave to amend this complaint to show their true names and capacities when same have been ascertained.
AND FOR A SECOND, SEPARATE AND FURTHER CAUSE OF ACTION, plaintiff alleges and says;
Plaintiff refers to Paragraphs I, II, III, IV, V, VI, and VII of her First Cause of Action and by reference makes them a part hereof.
That plaintiff believes herself to be the lawfully wedded wife of said defendant L. Ron Hubbard, in that she entered
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into said marriage in good faith, all as is alleged herein; that in the event the Court should find that she is not legally married to said defendant, plaintiff in such an event alleges that said marriage should be annuled [sic], and that she be awarded damages as hereinafter set forth; that said defendant wilfully [sic] and intentionally caused plaintiff to believe that she was his lawfully wedded wife, and if she in fact is not, said Hubbard in such an event should be ordered to pay the damages prayed for herein.
That plaintiff, believing that she was the lawfully wedded wife of said Hubbard, over a period of five years, devoted her life to said Hubbard, and served as wife, mother, housekeeper, author’s assistant, and pursuant thereto, washed dishes, cleared floors, scrubbed the floors and walls, cooked and served meals for said Hubbard, bore him a child, [loaned him over $20,000 – crossed out], and otherwise subjected herself to the course of cruelty alleged herein; that by reason thereof, the chances of plaintiff for happiness in life, and chances for a normal marriage have been diminished, and plaintiff has been prevented from following a profession of her choice, and has been so deprived of the “golden years of a woman’s life”, and by reason thereof, she has been damaged in the sum of $100,000.00 a year, making a total of $500,000.00 in all, if in fact it be found that she is not the lawfully wedded wife of said Hubbard, and has been subjected to the shame of a bigamous marriage.
That in the event it be found that plaintiff is not the lawfully wedded wife of said Hubbard, plaintiff should be accorded the right of a putative wife, and by reason thereof, should be allowed the same community property rights and interests in and to the property acquired by the plaintiff and the said Hubbard, following said ceremonial marriage on the 10th day of August,
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1946, all as is prayed for herein.
WHEREFORE, plaintiff prays judgment against defendant, L. Ron Hubbard, as follows;
For a Judgment of divorce from said defendant, that the bonds of matrimony heretofore and now existing between said parties be dissolved; That the custody of the minor child of the marriage, Alexis Valorie Hubbard, be awarded to plaintiff;
That defendant L. Ron Hubbard be ordered to pay to plaintiff reasonable alimony and support, and further provide reasonable support and maintenance for the minor child of the said marriage, Alexis Valorie Hubbard;
That the community property of the parties hereto be equitably apportioned, and the right, title and claim of interest of defendants herein other than said defendant Hubbard, be determined and adjudicated. That a lien be impressed upon the real property of said defendant Hubbard, to secure the payment of the sums of the alimony and support allowed herein;
That reasonable attorney’s fees and costs of suit be awarded plaintiff and her counsel, and that said defendant be ordered to pay the same. That in the event it be held that plaintiff is not a resident of the State of California, for the prescribed period, in such an event plaintiff prays that a decree of separate maintenance be entered herein, in lieu of a divorce;
That the Court appoint a receiver herein with customary powers to take over, manage, operate, and sell the business and properties of the community estate of the parties including the real property described in the complaint, said property to be held by said receiver subject to the order and direction of the Court, and that all defendants herein be ordered
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and directed to pay to said receiver, any community funds and deliver any community property they have in their possession, and that said receiver to be appointed ex parte, and that upon notice, said appointment of said receiver be confirmed and made permanent;
That said defendant Hubbard be restrained from injuring, molesting, or harming plaintiff, and be restrained from interfering with the custody of the minor child, and that upon the trial of the cause, said restraining order be made permanent;
That said Hubbard be restrained from concealing, dissipating, transfering [sic], or hiding any of the community property assets or property of the parties hereto; and
That if said marriage be held bigamous, that it be annuled;
That plaintiff be awarded damages in the sum of $500,000, if said marriage be found to be invalid;
That said Hubbard be ordered to submit to a psychatric [sic] examination as a protection to said infant child; and
That plaintiff be awarded any such other and further relief as is meet and proper.
WARNER & JACKSON
[signed: Caryl Warner]
Attorneys for Plaintiff
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STATE OF CALIFORNIA
County of Los Angeles )
SARA NORTHRUP HUBBARD being by me first duly sworn, deposes and says: that she is the plaintiff in the above entitled action; that she has read the foregoing Complaint for Divorce and knows the contents thereof, and that the same is true of her own knowledge, except as to the matters which are therein stated upon her information or belief, and as to those matters she believes it to be true.
[signed: Sara Northrup Hubbard]
Sara Northrup Hubbard
Subscribed and sworn before me this 23rd day of April, 1951.
[signed: B. R. Trout]
Notary Public in and for said (SEAL) County of Los Angeles, State of California