Tarr v. Narconon, Tarr's Opposition to Motion to Dismiss

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Ryan A. Hamilton

NEVADA BAR NO. 11587

HAMILTON LAW

5125 S. Durango Dr., Ste. C

Las Vegas, NV 89113

(702) 818-1818

(702) 974-1139

[email protected]

Attorney for the plaintiffs,

Cathy Tarr and Michael Tarr

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEVADA

CATHY TARR, a Virginia Citizen; and

MICHAEL TARR, a Florida Citizen,

Plaintiffs,

vs.

NARCONON FRESH START d/b/a RAINBOW

CANYON RETREAT; and DOES 1-100, ROE

Corporations I – X, inclusive,

Defendants.

Case No. 2:14-cv-00283-GMN-NJK

PLAINTIFFS’OPPOSTION TO

DEFENDANT’S MOTION TO

DISMISS COMPLAINT OR, IN THE

ALTERNATIVE, TO STRIKE OR

FOR MORE DEFINITE STATEMENT

Defendant urges this Court to dismiss Plaintiffs’ Complaint because Defendant claims it

cannot respond to allegations about its own treatment program. Without providing specific

examples, Defendant complains that Plaintiffs’ Complaint is fraught with editorial comments,

inflammatory language, impertinent allegations, and argument. The reality is less exciting: The

Complaint merely sets forth the factual allegations underlying Plaintiffs’ claims.

The Complaint is well within the federal pleading standards of Fed. R. Civ. P. 8.

Defendant’s Motion is a non-starter and should be denied. Accordingly, Plaintiffs oppose

Defendant’s Motion to Dismiss Complaint or, In The Alternative, to Strike or for More Definite

Statement (“Defendant’s Motion”).

Case 2:14-cv-00283-GMN-NJK Document 8 Filed 04/10/14 Page 1 of 14

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DATED this 10th

day of April, 2014.

HAMILTON LAW, LLC

By: /s/Ryan A. Hamilton

Ryan A. Hamilton

NV Bar No. 11587

5125 S. Durango Ste., C

Las Vegas, NV 89113

MEMORANDUM OF POINTS AND AUTHORITIES

INTRODUCTION

This case involves a bizarre, elaborate fraudulent scheme. In April of 2013, Plaintiff Cathy

Tarr was searching the Internet for a drug treatment program for her son, Michael. After being

routed to a Narconon representative from someone she believed was an independent consultant,

the Narconon representative persuaded Ms. Tarr to send her son to Narconon. To persuade her, the

Narconon representative promised that Narconon had a 76% “success rate,” that Narconon had a

sauna program that was “scientifically proven” to eliminate drug cravings, that her son would

receive one-on-one counseling from qualified counselors, and that the program was secular.

Believing these claims, Ms. Tarr paid Narconon’s $33,000 fee and sent her son to the program.

When Michael entered Narconon, however, Narconon treated him only with teachings and

practices from the religion of Scientology. Each of the promises the Narconon representative made

to Ms. Tarr was false. Narconon staff never even spoke to Michael Tarr about his substance abuse,

let alone counsel him about it. In lieu of treatment, Narconon had Michael unwittingly study and

practice introductory Scientology in its eight course books written by L. Ron Hubbard. And, the

sauna program Narconon claimed eliminated drug cravings was nothing more than a dangerous

Scientology ritual known as the “Purification Rundown.”


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Plaintiffs filed suit on February 24, 20141, seeking compensatory and punitive damages for

fraud, negligence, and breach of contract. As required under Fed. R. Civ. P. 9(b), Plaintiffs’

Complaint pleads Narconon’s fraud with particularity, setting out the “time, place, and manner”

for each fraudulent representation Plaintiffs allege. In so doing, Plaintiffs make factual allegations

about the contents of the Narconon course materials Michael Tarr received. Plaintiffs must do this

to allege with particularity the “manner” of Defendant’s false representations that Narconon is a

secular program that would provide Michael Tarr addiction counseling.

Further, in support of Plaintiffs’ prayer for punitive damages on their fraud claim,

Plaintiffs allege that Narconon knew that its promises to Ms. Tarr of a 76% “success rate” and a

sauna program proven to eliminate drug cravings were false. Plaintiffs allege that Narconon knew

these claims were false by quoting portions of deposition testimony from a prior case in which a

Narconon expert admitted they cannot back up these claims. As additional support for their prayer

for punitive damages, Plaintiffs allege that Narconon is being used to recruit members for the

Church of Scientology. To allege the requisite malice and oppression to support Plantiffs’ prayer

for punitive damages, Plaintiffs quote and attach Narconon’s own documents that suggest the

Narconon program is being used as a recruiting tool for Scientology. (Doc. 1, Exs. G, H).

Plaintiffs’ allegations in the Complaint are proper and comply with the requirements of

Fed. R. Civ. P. 8. Defendant’s complaints that it cannot form a responsive pleading are

disingenuous. The majority of the paragraphs in Plaintiffs’ Complaint make basic allegations

about Narconon’s own program. The information to answer these allegations is uniquely and

necessarily within Narconon’s knowledge. Such allegations may answered easily by quick

reference to Narconon’s course materials, or in a phone call between counsel and client.

1 Plaintiffs filed suit February 24, 2014, and served Narconon’s registered agent February 26,

2014. Pursuant to an extension, Narconon’s responsive pleadings was due April 8 and Narconon

filed the instant Motion April 8


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It is unsurprising that Narconon would rather not answer Plaintiffs’ Complaint. But the

instant Motion is wholly unfounded and should be denied in its entirety.

ANALYSIS

A. Ninth Circuit Precedent Under Fed. R. Civ. P. 8

Fed. R. Civ. P. 8 provides, in relevant part:

(a) Claim for Relief. A pleading that states a claim for relief must

contain:

…

(2) a short and plain statement of the claim showing that the pleader

is entitled to relief; and

(3) a demand for the relief sought, which may include relief in the

alternative or different types of relief.

…

(d) Pleading to Be Concise and Direct; Alternative Statements;

Inconsistency.

(1) In General. Each allegation must be simple, concise, and direct.

No technical form is required.

…

(e) Construing Pleadings. Pleadings must be construed so as to do

justice.

Fed. R. Civ. P. 8. Thus, Rule 8 requires Plaintiffs to plead short and plain statements of their

claims showing that they are entitled to relief. Further, Plaintiffs are required to plead their

allegations in a simple, concise, and direct fashion, and those pleadings must be construed to do

justice.

The rule in the Ninth Circuit is that “verbosity or length is not by itself a basis for

dismissing a complaint based on Rule 8(a).” Hearns v. San Bernardino Police Dep’t, 530 F.3d

1124, 1131 (9th Cir. 2008). Instead, for dismissal, the complaint must suffer some deficiency such

as being “replete with redundancy and largely irrelevant,” or being “conclusory and confusing.”


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McHenry v. Renne, 84 F.3d 1172, 1178 (9th Cir.1996)(affirming dismissal and noting that only

“by months or years of discovery and motions [could] each defendant find out what he is being

sued for”); Nevijel v. North Coast Life Ins. Co., 651 F.2d 671, 674 (9th Cir.1981)(affirming

dismissal of a 48–page complaint as “verbose, confusing, and conclusory”); Schmidt v. Herrmann,

614 F.2d 1221, 1223 (9th Cir.1980) (affirming dismissal of 30–page complaint because it was

“impossible to designate the cause or causes of action attempted to be alleged in the complaint”).

When faced with a complaint that suffers from one of these defects, a district court “should

first consider should first consider less drastic alternatives” than dismissal with prejudice.

McHenry, 84 F.3d at 1178. Indeed, because dismissal with prejudice is such a harsh remedy, it

should be imposed as a sanction only where there is evidence of bad faith or deceptive conduct

that “relates to the matters in controversy in such a way as to interfere with the rightful decision of

the case.” Hearns v. San Bernardino Police Dep't, 530 F.3d 1124, 1132 (9th Cir. 2008).

B. Plaintiffs’ Complaint

Plaintiffs’ Complaint is well-organized and coherent. Further, as Narconon appears to

concede, Plaintiffs state viable causes of action for fraud, breach of contract, and negligence.

Narconon complains in a cursory fashion that Plaintiffs’ allegations are inflammatory, immaterial,

redundant, editorial, incoherent, and argumentative. On the contrary, Plaintiffs simply have

provided the factual allegations that underlie and directly relate to their claims. As such, Plaintiffs’

Complaint gives Narconon fair notice of what is being alleged and amply satisfies Rule 8’s

requirements.

Section III of the Complaint, “Factual Allegations,” contains the bulk of Plaintiffs’ factual

allegations and is the Section about which Narconon complains. Section III is divided into five

subsections covering different topics, “A” through “E.” Each subsection sets forth allegations on

which Plaintiffs’ base their claims.


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First, subsection A, “Michael’s Entry Into The Narconon Program” sets forth allegations

relating to how Narconon made false representations to Ms. Tarr to induce her to send her son to

Narconon and pay Narconon $33,000. As required under Fed. R. Civ. P. 9(b), Plaintiffs plead

these matters with particularity and allege the “time, place, and manner of the alleged fraud.”

Accordingly, Plaintiffs allege that Ms. Tarr was referred by an “independent consultant” to

Narconon representative, Josh Penn, after she contacted a 1-800 number on a website. (Doc. 1, ¶¶

6 – 7). Plaintiffs then allege the specific false representations Penn made to Ms. Tarr as well as the

false representations contained in the Narconon correspondence sent to her. (Doc. 1, ¶¶ 8 – 13,

17). For instance, paragraph 17 sets forth false representations contained in the “Admission

Letter” that Ms. Tarr received on her son’s entry into the program. Specifically, the letter falsely

claimed that the Narconon program has a 70% success rate and that Narconon’s sauna program

has been “proven scientifically and medically” to “eliminate all future drug cravings.”

The remaining allegations in subsection A are basic factual allegations included simply to

describe what happened between the parties. (Doc. 1, ¶¶ 14 – 16, 18 – 19).

Next, subsection B, “The Narconon Program,” sets forth basic allegations about the

program that Narconon put Michael through and how the program operated. And, more

specifically, subsection B sets forth allegations underlying Plaintiffs’ claim that Narconon tricked

Michael into unwittingly studying and practicing Scientology in lieu of treatment. Plaintiffs make

these allegations, in part, by pointing out that the same Scientology concepts and practices found

in the book Narconon credits as being the inspiration for its program, “Scientology: The

Fundamentals of Thought,” are found throughout and comprise Narconon’s course materials.

Doc. 1, ¶¶ 20 – 41).

For example, paragraph 30 of the Complaint alleges that the Scientology concept known as

the “Eight Dynamics of Existence” is both discussed in “Scientology: The Fundamentals of

Thought” and taught in Book 6 of the Narconon program course materials. To respond to this


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allegation, Narconon would only need to quickly reference Book 6 of its course materials or

counsel could just ask the client. (Of course, Narconon is not required to respond as to the contents

of “Scientology: The Fundamentals of Thought.”)

Similarly, paragraph 24 provides, in relevant part, that “…[Training Routine] 3 from Book

1 of the Narconon program is used to teach students about the ‘Cycle of Communication.’ The

‘Cycle of Communication’ is a concept found early on in ‘Scientology: The Fundamentals of

Thought, the book Narconon credits as being the inspiration for its program. Again, to ascertain

whether Book 1 of the Narconon program teaches about the “Cycle of Communication,” counsel

would need only to reference the book or ask the client.

Subsection B also includes allegations about Narconon’s sauna program that Michael went

through, what Narconon calls the “New Life Detoxification” program. Id. at ¶ 42. Plaintiffs allege

that Narconon’s sauna is also a Scientology practice known as the “Purification Rundown.” Id. at

¶ 43. Narconon falsely claimed to Ms. Tarr that its sauna program was proven scientifically and

medically to eliminate all future drug cravings. Id. at ¶¶ 9, 17.

Plaintiffs then allege the basis for their belief that Narconon’s claims about its sauna

program are false: in a prior litigation, Narconon’s own medical expert admitted there was no

scientific basis to support those claims. Id. at ¶ 50. Plaintiffs quoted the expert’s relevant

testimony in their Complaint and attached the transcript of the deposition as Exhibit D to

Complaint. Plaintiffs’ purpose in quoting Narconon’s expert’s testimony and attaching his

deposition transcript is to support Plaintiffs’ claims for punitive damages in this case. That is,

Plaintiffs allege the basis for their belief that Narconon knew the claims about its sauna program

were false when making them to Ms. Tarr.

In Subsection C, “Narconon’s Fraudulent Business Practices,” Plaintiffs set forth

allegations about Narconon’s methods of inducing persons to enter their program, or to send a

loved one to it. These methods, such as promising a false 70% “success rate,” are the same


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methods Plaintiffs allege Narconon used to ensnare Ms. Tarr. Id. at ¶¶ 55 – 60. Plaintiffs again

quote the deposition testimony of Narconon’s own medical expert from a prior litigation who

admitted he “did not have a clear idea where that 70 – 70-something [success rate] number came

from.” Id. ¶ 59. Once again, Plaintiffs’ purpose in quoting Narconon’s expert is to provide

Plaintiffs’ basis for believing that the success rate Narconon claimed to Ms. Tarr was false, and

that Narconon knew it was false at the time.

Likewise, in paragraph 60, Plaintiffs provided another basis for their belief that the success

rate Narconon claimed to Ms. Tarr was false. Plaintiffs quote an internal email at Narconon,

obtained from a prior litigation, in which Narconon employees discuss how to handle a Better

Business Bureau Complaint. In the email, a Narconon employee states Narconon “do[es] not have

scientific evidence” for its claimed success rate. (Doc. 1, Ex. D).

The remainder of subsection C further sets forth other allegations that underlie Plaintiffs’

fraud claim. For example, Narconon promised Ms. Tarr that her son would receive extensive one-

on-one counseling from qualified counselors in a safe environment. Paragraphs 64 through 67 of

the Complaint allege that this promise was false because Narconon counselors are not certified in

addiction counseling (¶ 64), patients such as Michael Tarr do not receive any addiction

counseling, but only L. Ron Hubbard materials (¶ 65), Narconon has no on-site medical

professionals (¶ 66), and most Narconon staff members’ only qualification is that they completed

the Narconon program themselves. (¶ 67).

Subsection D, “Connection to the Church of Scientology,” sets forth factual allegations

that are relevant to Plaintiffs’ claim that Narconon provided Michael Tarr Scientology in lieu of

drug treatment. For example, paragraph 71 alleges that Narconon pays a licensing fee to the

Church of Scientology and the L. Ron Hubbard library to use the Church’s doctrine, or what is

known as its “technology” in Narconon’s course materials.


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Next, paragraphs 72 and 74 make allegations related to Narconon documents that underlie

Plaintiffs’ claim that Narconon provided Michael Tarr Scientology in lieu of drug treatment. (Doc.

1, Exs. G, H). These Narconon documents contemplate Narconon as being a source of recruitment

for the Church of Scientology. Plaintiffs’ allegations in paragraphs 72 and 74, and the exhibits

related to these allegations, are directly relevant to Plaintiffs’ claim that Narconon falsely

promised them its program was secular. Further, they support Plaintiffs’ prayer for punitive

damages.

Similarly, Plaintiffs allege facts in paragraphs 76 through 79 that show the intimate

connection between Narconon and Scientology. Plaintiffs allege that prominent members of the

Church of Scientology promote Narconon (¶ 76), and that Narconon proponents believe strict

application of L. Ron Hubbard’s technology alone should be used to treat drug addiction. (¶¶ 77 -

78). These allegations also underlie Plaintiffs’ claim that Narconon provided Michael Tarr only

Scientology and that the Narconon program is not secular in nature.

Lastly, in subsection E, “Harm to Plaintiffs,” Plaintiffs allege, as required for each of their

claims, how Narconon’s conduct damaged them. Narconon takes specific exception to paragraph

82 in which Plaintiffs allege that a Narconon Ethics Officer attempted to use Scientology doctrine

to show Michael Tarr how to avoid a common cold. Plaintiffs included this allegation because it

exemplifies how pervasive Scientology doctrine was during Michael’s time at Narconon and the

manner in which Narconon purported to “treat” Michael.

C. Plaintiffs’ Complaint Satisfies Fed. R. Civ. P. 8

And The Court Should Deny Narconon’s Motion In Its Entirety

Applying Ninth Circuit precedent to Plaintiffs’ Complaint, it becomes clear that Plaintiffs’

Complaint easily satisfies Rule 8. Plaintiffs’ Complaint is well-organized, coherent, and states

viable causes of action. Each allegation in the Complaint is directly relevant to Plaintiffs’ claims.

As such, the Complaint plainly satisfies Rule 8.


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The Ninth Circuit’s decision in Hearns v. San Bernardino Police Dep’t, 530 F.3d 1124,

1127 (9th Cir. 2008), is instructive. In Hearns, the Ninth Circuit held the district court abused its

discretion in dismissing the plaintiff’s 68-page amended complaint with prejudice under Fed. R.

Civ. P. 41(b). There, the Ninth Circuit reasoned that although the complaint “set forth excessively

detailed factual allegations, they were coherent, well-organized, and stated legally viable claims.”

Id. Accordingly, the Hearns Court concluded that neither the amended complaint, nor the 81-page

original complaint, violated Rule 8(a). Id. at 1130.

The Hearns decision teaches that Rule 8 is easily satisfied so long as the complaint is well-

organized and coherent. Indeed, the Hearns Court concluded that the plaintiff’s complaint satisfied

Rule 8’s requirements despite having a 42-page “Factual Background” section. Id.

If the complaint in Hearns satisfied Rule 8, there is no question Plaintiffs’ Complaint does

as well.

The decision in Hinchey v. Horne, CV-13-0260 PHX DGC, 2013 WL 1664704 (D. Ariz.

Apr. 17, 2013), is instructive as well. In Hinchey, the defendants sought to strike the plaintiff’s 72-

page complaint with ten exhibits as a violation of Rule 8(a)(2). Id. at *1. Quoting Hearns, the

district court denied the motion in full:

[T]he complaint at issue here was not “replete with redundancy and

largely irrelevant.” Cf. McHenry, 84 F.3d at 1177. It set out more

factual detail than necessary, but the overview was relevant to

Plaintiff's causes of action .... Nor was it “confusing and

conclusory.” Cf. Nevijel, 651 F.2d at 674. The complaint is logically

organized, divided into a description of the parties, a chronological

factual background, and a presentation of enumerated legal claims,

each of which lists the liable Defendants and legal basis therefor.

The [allegations] contain excessive detail, but are intelligible and

clearly delineate the claims and the Defendants against whom the

claims are made.... Here, the Defendants should have no difficulty in

responding to the claims with an answer and/or with a Rule 12(b)(6)

motion to dismiss.

Hinchey v. Horne, CV-13-0260 PHX DGC, 2013 WL 1664704 (D. Ariz. Apr. 17, 2013)(quoting

Hearns, 530 F.3d at 1132.


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The Hinchey Court also dismissed defendants’ arguments that the complaint contained

superfluous factual details and exhibits. The court reasoned that although the additional details

may not have been necessary they did make the plaintiff’s claim more plausible. Hinchey, 2013

WL 1664704, at *3. Accordingly, the additional details did not make the complaint “replete with

redundancy and largely irrelevant.” McHenry, 84 F.3d at 1177. In addition, the court ruled that the

plaintiff’s ten exhibits constituting 150 pages also did not violate Rule 8 because defendants need

only answer allegations in the complaint itself. Id.

This situation here is similar to Hinchey and Hearns. Defendants claim Plaintiffs’

Complaint contains unnecessary factual detail. Although Plaintiffs contend that all of the factual

allegations in their Complaint are necessary and directly relevant, Hearns and Hinchey make clear

that even if defendants are correct it is of no moment. As in Hinchey, the factual allegations in

Plaintiffs’ Complaint relating to what Narconon’s program consists of and Narconon’s intimate

connection to Scientology make Plaintiffs’ claims more plausible. And, as the Hinchey Court

ruled, this does not amount to a Rule 8 violation.

Tellingly, Narconon does not cite the Hearns case in its Motion despite the fact that the

decision discusses nearly every other case Narconon cites. Instead, Narconon places principal

reliance on McHenry v. Renne, 84 F.3d 1172 (9th Cir.1996), and other cases that are wholly

inapposite. In McHenry, the Ninth Circuit dismissed the plaintiffs’ third amended complaint with

prejudice because it was fifty-three pages and mixed allegations of “relevant facts, irrelevant facts,

political argument, and legal argument.” Id. at 1174. After reading the plaintiffs’ complaint, the

McHenry Court was still unclear which legal claims plaintiffs were raising against which of the

multiple defendants. Id. at 1180. This is a far cry from Plaintiffs’ Complaint here.

Narconon characterizes Plaintiffs’ allegations in paragraphs 21 through 54 as editorial

“editorial comments.” Defendant’s Motion at 5 – 6. To the contrary, these are factual allegations


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about the treatment program Narconon put Michael through. These allegations are at the heart of

this case.

Narconon also asserts that the undersigned is attempting to garner media attention with

Plaintiffs’ Complaint. In support of this assertion, Narconon points out that the undersigned

advertises for cases like this on his firm’s website and has filed three other cases similar to this

one.

Of course, there is nothing unusual or improper about an attorney advertising for cases on

a website. Nor is at all strange that an attorney might have multiple cases against the same

defendant. Narconon’s argument is frivolous.

Finally, Narconon’s request for a More Definite Statement and its claim that it cannot

respond to Plaintiffs’ allegations is wholly disingenuous. It bears repeating that the most of the

allegations relate to what is contained in Narconon’s own treatment program. Thus, the

information to answer these allegations is uniquely and necessarily within Defendant’s

knowledge.

For example, Plaintiffs allege in paragraph 20 that “[t]he Narconon ‘Treatment’ Program

consists of two components: (1) course materials consisting of eight books by L. Ron Hubbard;

and (2) a sauna and vitamin program known as the ‘New Life Detoxification Program.’” Similarly,

paragraph 31 alleges that Narconon has students demonstrate their understanding of a Scientology

concept known as the Eight Dynamics of Existence by making clay sculptures. There is no reason

Narconon should have any difficulty responding to these basic allegations about its own program.

And, of course, Narconon is free to deny the allegations in accordance with Fed. R. Civ. P.

8(b)(2).


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Requiring a defendant to answer basic allegations about its own program is hardly

unreasonable or burdensome. It does not violate Fed. R. Civ. P. 8, nor is it good grounds for a

motion to strike or for a more definite statement.

For all these reasons, the Court should deny Narconon’s Motion in its entirety.

DATED this 10th

day of April, 2014.

Respectfully submitted,

HAMILTON LAW, LLC

By: /s/Ryan A. Hamilton

Ryan A. Hamilton

NV Bar No. 11587

5125 S. Durango Ste., C

Las Vegas, NV 89113


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CERTIFICATE OF SERVICE

I certify that I am an employee of Hamilton Law, LLC, and that on the 10th

day of April,

2014, I caused a copy of the foregoing Plaintiffs’ Opposition to Defendant’s Motion to Dismiss

Complaint or, In the Alternative, to Strike or for More Definite Statement to be served via

the CM/ECF electronic system to all parties on the service list:

S. Brent Vogel

Alayne M. Opie

LEWIS BRISBOIS BISGAARD & SMITH, LLP

6385 S. Rainbow Boulevard, Ste. 600

Las Vegas, Nevada 89118

/s/Ryan A. Hamilton


Documents

Tarr v. Narconon, Tarr's Opposition to Motion to Dismiss