WARNER & JACKSON
639 South Spring Street
Los Angeles 14, California
Tucker 9171
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, )
)
Plaintiff, )
)
vs. )
)
L. RON HUBBARD, also known as )
LAFAYETTE RONALD HUBBARD; Los )
Angeles Department HUBBARD DIANETIC ) No. D
RESEARCH FOUNDATION, a partnership; ) COMPLAINT FOR DIVORCE
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, )
)
Defendants. )
------------------------------------------)
[Stamped: D414408]
COMES NOW the plaintiff and for cause of action against
defendants alleges and says:
I
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 un-
married, and plaintiff relying upon said representation, and hav-
ing 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.
II
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.
III
Statistical facts required by section 426a of the Civil
Code of Procedure are:
(1) Place of marriage; Chestertown, Maryland;
(2) Date of marriage; On the 10th day of August
1946;
(3) Date of separation; On or about the 24th day of
February 1951;
(4) Time elapsing between the date of marriage and
the date of separation; Approximately four years, six months
and twelve days; and
(5) There is one child of the marriage; Alexis
Valorie Hubbard, age 13 months.
IV
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 suffer-
ing during the past five years of the married life of the parties,
consisting in part as follows;
(a) 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 success-
ful marriage, repeatedly subjected plaintiff to systematic torture,
including loss of sleep, beatings, and strangulations and scientific
torture experiments, including the following:
(b) 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.
(c) That at said time and place, said Hubbard systemati-
cally 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.
(d) 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.
(e) That shortly following Christmas, 1950, 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.
(f) 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.
(g) 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 immedi-
ately advised said Hubbard of said diagnosis.
(h) 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.
(i) 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.
(j) 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.
(k) 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.
(l) 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.
VI
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.
VII
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 allow-
ed herein.
VIII
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.
IX
That said Hubbard departed from the State of California
on the 24th day of February, 1951, and ever since has remained out-
side 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.
X
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.
XI
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;
I
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.
II
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.
III
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.
IV
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;
(1) For a Judgment of divorce from said defendant,
that the bonds of matrimony heretofore and now existing between
said parties be dissolved;
(2) That the custody of the minor child of the
marriage, Alexis Valorie Hubbard, be awarded to plaintiff;
(3) 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;
(4) 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.
(5) 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;
(6) 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.
(7) 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;
(8) 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;
(9) 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;
(10) 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
(11) That if said marriage be held bigamous, that it be
annuled;
(12) That plaintiff be awarded damages in the sum of
$500,000, if said marriage be found to be invalid;
(13) That said Hubbard be ordered to submit to a
psychatric [sic] examination as a protection to said infant child; and
(14) That plaintiff be awarded any such other and
further relief as is meet and proper.
WARNER & JACKSON
[signed: Caryl Warner]
By: ________________
Caryl Warner
Attorneys for Plaintiff
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STATE OF CALIFORNIA )
County of Los Angeles ) ss.
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