Lisa Jan Precious
c/o 12358 Ventura Blvd. #245
Studio City, California (18 U.S.C. 1342)
Lisa Jan Precious
In propria persona [NOT PRO SE]
In the superior court for Los Angeles county, California
FOOTNOTE 1: Concurrent with and equivalent to the district court as created in the Constitution of the State of California of 1849, and the seventeenth judicial dietrict, see Stats 1872, ch. CXIV, p. 116
Stephen Mitchell; Lisa Jan Precious; Kathleen
DAVID MISCAVIGE, a person, in the capacity
as Chairman of the Board of the Religious Technology Center and Inspector
General of the Church of Scientology
MIKE RINDER, a person, in the capacity as head of the Office of Special Affairs International
JOHN/JANE DOE #1, a person, in the capacity as head of the L. Ron Hubbard Library
JOHN/JANE DOE, #2-99
Case No. BC175367
Verified Statement of Demand for Damages of
Lisa Jan Precious
in support of the Verified Complaint for Libel
The libelous publication complained of
in the above numbered case is a real and far reaching
source of potential damage to the life and livelihood of Lisa Jan Precious, one of this
To be alleged as, or perceived as, a "tax protester", "criminal", "insane", and/or "squirrel" will have a negative impact on the significant careers of this Plaintiff, and will have a limiting effect in furthering her already established careers which are reliant on a positive reception by the public.
FOOTNOTE 2: Within Scientology, the term "squirreling" means "altering Scientology" and "off-beat practices".
1. Premiere Parent. This parent guidebook to Los Angeles was originally researched, written and self-published by this Plaintiff. The first printing sold out in six (6) weeks. It went on to become a regional bestseller, selling at locations such as B. Dalton, Waldenbooks and Barnes & Noble bookstores. It achieved the attention of Grove Press of New York which resulted in a contract with this Plaintiff. As the creator and author of Premiere Parent guidebooks this Plaintiff's most recent editor indicated that the marketing plan would position this Plaintiff as the "Martha Stewart" of motherhood. This would include merchandising, cross promotions and media shows. This Plaintiff's agent, Richard Barber, has indicated that the development of one book was quoted at $200,000 and that a publishing company's expectations are to create a return of no less than 10 times their development costs. The complete project of Premiere Parent, is a four book series in development. The total expected initial value potential would be $8,000,000.00 dollars for the first sales phase.
FOOTNOTE 3: Martha Stewart made her reputation as the head of etiquette and entertainment in the White House. She has parlayed this into a multi-million dollar industry of home-decorating, entertainment and food books as well as a television show and most recently her own line of home goods for K-Mart.
FOOTNOTE 4: $200,000.00 x 4=$800,000 then multiplied by 10 based on Grove Press projections.
la. This Plaintiff's Agent has negotiated the rights to the researched and written manuscripts to revert back to this Plaintiff, who is currently in development of a website to sell the books directly. In addition, this Plaintiff has created a "Family Travels and Adventures"television show pilot for the NATPE convention to sell the show directly to cable and TV networks. Merchandising and cross promotions are also planned.
lb. In a wholesome motherhood market, it is not irrational to presume that no one would want family information, travel advice, or products, etc., from a "criminal" or "tax protester". Merchandising or cross promotions, such as this Plaintiff did with Beech-Nut (the sponsor of the first book) would be out of the question. Most of the prospective merchandising companies are publicly held companies which due to fiduciary responsibilities could not afford to align with "criminals" and risk losing or offending stockholders who would object to the "stigma" of associating with "criminals".
1c. It is indisputable that the libelous publication has great and extensive potential to damage the planned future growth of the foregoing project, in that the photograph of this Plaintiff published on the front page of the libelous publication is a copy of the very same photograph of this Plaintiff published on the cover of the Premiere Parent book (see Exhibit A). It must be noted that this particular photograph is clearly disclosed as having a copyright, stated within the first page of the book. The additional matter of copyright infringement will be dealt with in the proper venue separate from this complaint.
1d. The initial success of the original edition of the Premiere Parent guidebook is indisputable. Add to that this Plaintiff's extensive background in marketing and public relations it is reasonable to believe and expect that the future Premiere Parent's book sales, television show, merchandising and cross promotions would result in a significant revenue potential in the millions of dollars. This future potential is in serious jeopardy as a result of the libelous publication.
FOOTNOTE 5: Marketing and P.R. career includes: V.P. of Marketing L Media for AB Productions of Twentieth Century Fox; One of 3-Man Marketing Launch Team for UPN Television Network; Republican Marketing & Media Campaign specialist; 14 years with own company as publicist and producer with such clients as The Republican National Committee, Columbia studios, Princess Cruises, Moet & Chandon, City of Dallas and Forth Worth, Arlington County, and Michael Landon.
2. Acting: "Mother" and "professional" type roles. May 1997 Coast to Coast talent agency approached this Plaintiff for "mother" roles. This Plaintiff is currently a character in the global cybersoap "Confessions" (www.confessionstv.com) .
3. Politics. This Plaintiff's very first professional production job was as the assistant to the producer of the 1980 Republican National Convention in Detroit. This developed into training and placement in California as a campaign marketing and media specialist. The first video produced solely by this Plaintiff was for Betty Ford as dedication piece for the Betty Ford Center in Palm Springs. Guests present at this debut of the video were Johnny Carson, Bob Hope and Frank Sinatra. Additionally, this Plaintiff produced a segment for the next convention which aired simultaneously on the three major networks. At that same convention this Plaintiff was hired by Dennis Revell (Maureen Reagan's husband) to teach the Republicans how to satellite electronic press kit (EPK's) coverage.
3a. This Plaintiff has an extensive career and has developed significant contacts in politics which was acknowledged by Scientologists when this Plaintiff was hosted at Flag headquarters in Florida specifically for a political event and placed this Plaintiff at the table of Peter Grace, of President Reagan's Peter Grace Commission. It is this Plaintiff's intention to use the motherhood profile to reenter the political realm via school boards or Congress. It is indisputable that the existence of the libelous publication has rendered this as practically impossible. Given the nature of political campaigns, this libelous publication would certainly be resurrected and displayed by the political opposition.
4. Documentary Producer. Along with another Scientologist, Tim Melchior, this Plaintiff co-produced a half hour show for the History Channel which aired in May 1997. It was called "Steinbeck's Cannery Row". This Plaintiff, in association with Tim Melchior, had many plans to use this show as a springboard for new projects. With regard to this particular effort, this Plaintiff believe that the damage of the libelous publication has already taken its toll. Tim Melchior was contacted by this Plaintiff to inform him of the airing date, this Plaintiff was told that he (Tim Melchior) could no longer do business with this Plaintiff.
5. Public Relations & Marketing Company. The basic service which provides revenue and a source of new clients is that of public relations and marketing. This Plaintiff's original corporation, Cross Communications, and currently Precious P. R. & Productions are a result of this continuous financial base. The Church of Scientology acknowledged this expertise when this Plaintiff set up a special PR division for them during the Portland Crusade, then went on to establish and teach them how to run a satellite electronic press kit public relations campaign. There are commendations in this Plaintiff's Scientology folder regarding this extensive volunteer effort.
5a. It must be noted that the value of an active public relations company has already been set by another Scientologist. Michael Baybak's public relations company sought $60 million in damages in a libel suit against a major national publication. This is confirmed by a Scientology press release by Teisa Goodman headlined as "Multi-million Suit Against TIME Magazine to go to Trial".
6. Based on all the foregoing facts and evidence, clearly demonstrating that a viable career is already in place for this Plaintiff, Lisa Jan Precious, a career that can be severely damaged or even terminated as a result of the allegations of being a "criminal" and of being "insane" within the libelous publication, it is indisputable that this Plaintiff, Lisa Jan Precious must be awarded significant monetary damages to offset the potential damages that threaten the destruction of this well established professional career. This Plaintiff, Lisa Jan Precious hereby demands that damages be paid in an amount to be no less than $70,000,000.00.
I, Lisa Jan Precious, hereby swear under penalty of perjury, under the law of the Land in California, one of the United Staten of America, that paragraphs 1 through 6 hereinabove are true and correct and so done in good faith to the best of our knowledge and belief.
Subscribed and sworn this twenty-ninth day of the seventh month, in the year A.D. nineteen hundred ninety seven.
[L.S.] (SIGNATURE: LISA PRECIOUS) seal
Lisa Jan Precious