Debunking Alleged "Crystal Skulls"

[educatedindian]

mibbyagain" <mibbyagain@yahoo.com>  Add to Address Book
Date: Mon, 27 Sep 2004 19:41:26 -0000
Subject: [newagefraudsplastichshamans] Re: Curvey the Oracle Skull plays Truth or Dare

   
--- In newagefraudsplastichshamans@yahoogroups.com, "barnaby_mcewan"
<barnaby_mcewan@y...> wrote:
> --- In newagefraudsplastichshamans@yahoogroups.com, Peter Webster
> <peterweb@b...> wrote:
> > I spent two hours last night, cruising around the site and> > just scratched the surface.
> >
> >
> > http://skepdic.com/crystalskull.html
> >
> > Skinny Butt
>
> A couple of other good ones:
>
> http://www.guardian.co.uk/life/badscience/
>
> Not encyclopaedic; brief but pithy items, a new one every Thursday.
>
> http://www.quackwatch.org/
>
> This is encyclopaedic, with a capital E.
>
> http://www.quackwatch.org/01QuackeryRelatedTopics/Cancer/
twofeathers.html
>
> I bet William Two Feather will be pissed that he didn't think of that.

I recently emailed Quackwatch telling them it might be of interest to them that these various scam artists selling "traditional Native methods" aren't really Indian. Hell, one element of Lakota medicine is the idea that diseases are caused by animals too small to be seen. Of course, that's so close to mainstream medicine that few altmedders
will deal with it. These are the same people who advocate the principle that like cures like but say vaccines cause autism. (It takes a special kind of scum to risk the lives of small children as
part of a scam.)

[educatedindian]

mibbyagain" <mibbyagain@yahoo.com>
Date: Sun, 26 Sep 2004 16:34:13 -0000
Subject: [newagefraudsplastichshamans] Re: Curvey the Oracle Skull plays Truth or Dare

Innewagefraudsplastichshamans@yahoogroups.com, "educatedndn" <bigi_again@y...> wrote:
>newagefraudsplastichshamans@yahoogroups.com, "astronomy_gal"
> <astronomy_gal@y...> wrote:
> > --- In newagefraudsplastichshamans@yahoogroups.com, "mibbyagain"
> > <mibbyagain@y...> wrote:
> > > Here's a good description of the whole crystal skull phenomenon
> in > > New
> > > Age:http://skepdic.com/crystalskull.htm
> >
> > Here's a link on the 13 crystal skulls mentioned next door.  It > > mentions American Indians so I post it here for further info.  It > > gets really far out  LOL
> >
http://groups.msn.com/StarChildren/the13crystalskulls.msnw
> > http://www.bryandeflores.com/crystalskulls.html
> >
http://www.mysteriousamerica.net/interviewwithjos.html
> Shapiro's credibility is shot, he promotes frauds like Harley and > Jamie Samms.
>
> "Editor: I once read that a Cherokee medicine man reportedly told a > legend of how when twelve talking quartz crystals were brought
> together, then important messages would be conveyed. Ever hear of > anything similar?
>
> Joshua Shapiro: The Cherokee medicine man you are referring to is > known as Harley Swiftdeer. At the time of your interview, I am in correspondence with him to investigate the information that is
> discussed about such a circle of crystal skulls (not clear if the > number is twelve or thirteen). I have heard about his information > before during my travels and there is an interview with him in the
> crystal skull book written by Morton and Thomas. He has describes > these particular skulls as the Talking Skulls and that each one came from a human-type world of which the Earth was one of these.
> Swiftdeer claims this legend has been handed down by the elders of the Twisted Hairs, a Medicine Society which have representatives
> from hundreds of different indigenous tribes.

Err . . . ? What is it? Like the Holy UN?

> There are two other sources I have encountered discussing a similar story or legend which we refer to in our new book. Both of these sources say this legend (or oral tradition) speaks about a set of 13
> Crystal Skulls that are known to the Native American in North America. These crystal skulls are referred to as the Grandmothers or Clan Mothers (Jamie Sams discussed this in one of her books"

Harley and Jamie AGAIN! These fakes are more incestuous than, well, Harley's story of his elder male relatives teaching him to masturbate.

[educatedindian]

educatedndn" <bigi_again@yahoo.com> Date: Sun, 26 Sep 2004 15:59:59 -0000
Subject: [newagefraudsplastichshamans] Mary Thunderthighs 70s TV Show Wisdom

--- In newagefraudsplastichshamans@yahoogroups.com, "E Bryant Holman" <bryanth@p...> wrote:
> JoAnn, Max, and Mary Thunder
>
http://www.marythunder.com/CrystalSkulls/MaxTheCrystalSkull/MaryThunderMaxTheCrystalSkull.htm
> JoAnn and Max seem to have one thing that is very much a part of their overall theme - the connection to Native Americans. They try to
milk that aspect for all that it is worth, and I really think that JoAnn is, in spite of her protests, raking in a pretty good chunk of cash with all of this.

That article by Thunderthighs is pretty hilarious, though unintentionally. She gets all ofher "wisdom" from imitating old TV shows.

"Phone rings again & yes, it was Suzanne. She shared what had happened, At this point I surrendered. As I was hanging up the telephone & resuming my place on the couch as I watched the
show...Kung Fu, I heard: In this imperfect world perfection is an illusion. Thus, our judgements are illusions because they have no basis. Pretty interesting...."

You must grab the pebble out of my hand, grasshopper...

"She told me the story of Max, how she had gotten him & how long he had been in the closet. Then she said, "Hey, you haven't spent any time with Max." Well, I asked if it would be possible to bring in the sacred pipe? Joanne thought for a minute & said, "Why Not, Let's do Ceremony." So, we brought in the sacred Pipe & Drum...."

Come on everybody, let's sing a song
Come on get happy!
(Partridge Family Theme)

[educatedindian]

E Bryant Holman" <bryanth@presidiotex.com>  
Date: Sat, 25 Sep 2004 21:34:49 -0500
Subject: [newagefraudsplastichshamans] Re: Curvey the Oracle Skull plays Truth or Dare
   
<<From:  "mibbyagain" <mibbyagain@y...>
Date:  Sat Sep 25, 2004  1:16 pm
Subject:  Re: Curvey the Oracle Skull plays Truth or Dare
You'll have to tell me more about this name confusion.>>

------- ------- -------
Okay, here is the situation. I may be wrong about Ravenia the kinky internet dominatrix
http://www.ladyravenia.com/  being the same person as Ravenia the crystalskull matrix monger http://www.thoughtandmemory.com/collection1.htm
But when you look up the name "Ravenia" in a search engine, that is what you get - there two (or is it one?) person(s). http://www.zapatistas.org/ravenia.gif
I thought there was a strong passivity that they were the same person, based on certain features of the faces, but now I am having my doubts. In any event, I think one of them is in Texas and the other in California.
But, in order to not stretch myself to thin, I want to focus on the Texas skull http://www.click2houston.com/news/1762331/detail.html
http://www.v-j-enterprises.com/maxcs.html
Max, the crystal skull who is part of this dog and pony show that this Texas woman puts on for new agers, is connected with this character who called
himself "Norbu Chen", but in a lawsuit which he and his organization, The Chakpouri Ling Foundation, lost out to California lawyer Ford Greene representing HARLA ANN SIMON in a lawsuit that alleged such things as the coercion of sexual favors by way of Chen (or Chan) being Simon's guru and supposedly having the rights to that sort of thing. He also conned her into
signing over her inheritance to her, and a lot of other acts which some of them are even more despicable than these. JoAnn, however, due to the
meddling of a person whose name I am not going to mention anymore, actually contacted me and claimed that the Norbu Chen (or Chan) who lost this lawsuit is not the same one whom she knew! So there we have a claim that there must
have been two guys with the same name AND having the same name for their organizations "The Chakpouri Ling Foundation". But JoAnn assured me that this is a coincidence that could easily occur, since Norbu is a common Tibetan name! The weird thing about names, in this case, is that in one
report he will be "Chen", in another "Chan", and the Houston TV station that interviewed JoAnn spelled it "Chin".
Here is what Ford Greene, Esq., said about Norbu: "Chan was a charlatan, cult leader, compulsive liar and sexual predator. I prosecuted the attached lawsuit against Chakpori Ling Foundation. After three weeks of trial, they
settled."
A copy of the lawsuit was already posted here earlier by Al.
Here are some more details about "Max"
JoAnn Parks cites God himself in this note to her admirers:
*******
PERSONAL MESSAGE FROM JOANN PARKS
We feel "MAX" will continue to be a Joy and Inspiration to many thousands of people to come, that he has been exposed to us at this time to Mankind for a particular purpose, and that purpose is only just beginning to be realized.
I am so thankful to God to be a part, in whatever small way that may be, to help us understand who we are and where we are going. God has given us many gifts and tools in many forms to help us along our own path of Truth. Is "MAX" simply a tool for us, given to help us along?
WE know "MAX" is special, and Carl and I think you for this opportunity to share "MAX" with you. We hope he leaves you with that special little
something which he does so well.
Always,
JoAnn & MAX
******
Spoof interview with Max
http://accessnewage.com/articles/humor/skull.htm
Max has a gig coming up! http://www.jodiserota.com/crystal_skulls_max.htm
JoAnn, Max, and Mary Thunder
http://www.marythunder.com/CrystalSkulls/MaxTheCrystalSkull/MaryThunderMaxTheCrystalSkull.htm
A former astronaut turned UFO and paranormal investigator gets to be buddies with Max's handlers http://www.uri-geller.com/mitchell1.htm
A very off the wall interview and article about Max
http://www.xenophilia.com/zb/zb0041.htm
JoAnn and Max seem to have one thing that is very much a part of their overall theme - the connection to Native Americans. They try to milk that aspect for all that it is worth, and I really think that JoAnn is, in spite of her protests, raking in a pretty good chunk of cash with all of this.

[educatedindian]

"educatedndn" <bigi_again@yahoo.com>  Add to Address Book
Date: Wed, 22 Sep 2004 23:03:25 -0000
Subject: [newagefraudsplastichshamans] Lawsuit Over Crystal Skull

   
Hey Bryant, why not cross post anything that seems interesting in
your group to this one as well? That'd esp include factual links or
docs like this one.

---

HUB LAW OFFICES
Ford Greene, Esquire
711 Sir Francis Drake Boulevard
San Anselmo, California 94960-1949
Telephone: (415) 258-0360

Attorney for Plaintiff
HARLA ANN SIMON


     SUPERIOR COURT OF THE STATE OF CALIFORNIA

     IN AND FOR THE COUNTY OF SONOMA



HARLA ANN SIMON, an individual,      )      No.      175898
                                         )
                       Plaintiff,      )      THIRD
AMENDED COMPLAINT FOR
                                         )      FOR
DAMAGES FOR FRAUD,
vs.                                          )
     INTENTIONAL INFLICTION
                                         )      OF
EMOTIONAL DISTRESS,
CHAKPORI-LING FOUNDATION, a             )      NEGLIGENT INFLICTION
OF  
not for profit Louisiana                  )      EMOTIONAL
DISTRESS,
corporation; CHAKPORI-LING            )      BATTERY, NEGLIGENCE,
BREACH
FOUNDATION, INC., a not for            )      OF STATUTORY DUTY TO
PAY
profit California corporation;      )      WAGES AND OVERTIME,      
KATHLEEN LYNCH, individually and       )      CONVERSION, and
INVASION OF
as employee of Chakpori-Ling             )
     PRIVACY                    
Foundation and/or Chakpori-Ling      )
Foundation, Inc.;                         )
and DOES 1 to 50, inclusive,            )
                                         )
                       Defendants.      )
                                         )
                                  )
     Pursuant to the Order of this Court, comes now plaintiff
HARLA ANN SIMON and submits her third amended complaint for damages
against the hereinafter named defendants, and each of them.
Therefore, plaintiff pleads her third amended complaint as follows:
///
///
///
     GENERAL ALLEGATIONS
     1.      Plaintiff is a competent adult and a resident of the
County of Marin, State of California.
     2.      Defendant CHAKPORI-LING FOUNDATION is a not for
profit corporation organized in the State of Louisiana which is
doing business in the State of California primarily in the County of
Sonoma and taking advantage of California laws, rights and
privileges.
     3.      Defendant CHAKPORI-LING FOUNDATION, INC. is a not
for profit corporation organized in the State of California which is
doing business in the State of California and taking advantage of
California laws, rights and privileges and which has its principal
place of business in the Town of Forestville, County of Sonoma,
State of California.
     4.      NORBU CHAN ("CHAN") is the founder and controller of
CHAKPORI-LING FOUNDATION, INC., and CHAKPORI-LING FOUNDATION,  and
in doing the acts herein alleged was acting both as the controller
of said entities and also as an individual.
     5.      At all times mentioned herein defendants CHAKPORI-
LING FOUNDATION, INC., and CHAKPORI-LING FOUNDATION, will be
referred to as the "charitable corporations."
     6.      Plaintiff is informed and believes and alleges
thereon that at all times mentioned herein there was such a unity of
interest and control between CHAN and said charitable corporations
that said corporations functioned as the alter ego of CHAN to the
extent that their separate corporate existence should be dispensed
with and that said corporations and CHAN should be treated as one.
     7.      At all times mentioned herein defendant KATHLEEN
LYNCH ("LYNCH") was an officer and employee of the charitable
corporations and in every act herein alleged was acting within the
scope and course of her employment by said charitable corporations.
     8.      At all times mentioned herein CHAN was licensed by
the California Board of Medical Quality Assurance as an
acupuncturist.
     9.      The true names and capacities of the defendants
named herein as DOES 1-50, inclusive, whether individual, corporate,
associate or otherwise, are unknown to plaintiff who therefore sues
such defendants by fictitious names pursuant to California Code of
Civil Procedure ?474. Plaintiff is informed and believes that Doe
defendants are California residents. Plaintiff will amend this
Complaint to show such true names and capacities when they have been
determined.
     10.      Plaintiff is informed, believes and thereby alleges
thereon that at all times mentioned herein each of the defendants
was the agent, employee, partner, coconspirator or representative of
the remaining defendants and was acting at least in part within the
course and scope of said relationship.

[educatedindian]

      11.      CHAN conspired with LYNCH and DOES 1 to 10 to take
advantage of plaintiff by exploiting her for money, labor and <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a>
and in doing the acts hereinafter alleged acted in furtherance of
said conspiracy. Said conspiracy and the acts in its furtherance
proximately caused damage as hereinafter alleged.
     12.      CHAN directs, operates, supervises and controls a
certain encampment located at 10400 Highway 116 in Forestville,
California, which he describes as a monastery.
     13.      At all times mentioned herein CHAN held himself out
as a spiritual leader and advisor who possessed special powers which
plaintiff did not herself possess.
     14.      At all times mentioned herein CHAN instructed
plaintiff that he could and would act in her best interests only if
she reposed her complete trust and total confidence in him and
absolutely obeyed and submitted to his superior wisdom and knowledge.
     15.      As a result of CHAN's instigation plaintiff reposed
her trust and confidence in CHAN and obeyed his instructions and
submitted to his commands with the expectation that he was acting in
her best interests as her spiritual advisor in a special and
confidential relationship.
     16.      Plaintiff was kept at CHAN's monastery from January
1982 through August 11, 1988.
     17.      Plaintiff was unaware that CHAN had engaged in any
misconduct as hereinafter alleged because from January 1982 through
September 1988 plaintiff was unduly influenced and subjected to
coercive persuasion which had been employed by CHAN as hereinafter
alleged. Because of the mistreatment of plaintiff by CHAN, as
hereinafter alleged, plaintiff did not physically leave the
monastery until August 11, 1988. At that time she left because she
was physically beating and bruising herself on a daily basis in an
attempt to escape CHAN's domination.  She also had confided in a man
who helped her start to understand that CHAN was not omnipotent, and
therefore, not acting in her best interests.  She came to the
understanding that CHAN ruled the monastery with unqualified power
and could engage in any conduct he chose without any control
whatsoever. The combination of these factors coalesced and provided
plaintiff with the insight that she must escape the monastery.  This
is what occurred on August 11, 1988.
     FIRST CAUSE OF ACTION - FRAUD
     18.      Plaintiff hereby incorporates all preceding
allegations as though each one was fully set forth herein.
     19.      In January 1982 CHAN represented to plaintiff that
if she moved into his monastery she would have her own cottage in
which to live and CHAN would guide her and act in her own spiritual
best interests.
     20.      At the time CHAN made said representations, he knew
that they were false.
     21.      The true facts were that CHAN wanted to dominate,
control and unduly influence plaintiff so that he could exploit her
for money, labor, adulation and as a tool by which to manipulate
others for his own perverse forms of <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a>ual gratification.
     22.      At the time CHAN made such representations he knew
were false, he made them with the intent that plaintiff would rely
upon them so as to place herself in the isolated and controlled
environment at the monastery.  There CHAN imposed techniques of
coercive persuasion upon plaintiff without her knowledge or consent.
     23.      Plaintiff relied on CHAN's representations to her
detriment and said reliance was justified.
     24.      Had plaintiff known that she never would have been
provided her own cottage, and had plaintiff known that CHAN intended
to unduly influence and coercively persuade her, she would not have
relied on the representation set forth above.
     25.      As a proximate result of plaintiff's reliance on the
misrepresentations of CHAN she suffered injury and damage.

[educatedindian]

      25.      As a proximate result of plaintiff's reliance on the
misrepresentations of CHAN she suffered injury and damage.
     26.      The injury and damage suffered by plaintiff
includes, but is not limited to, placing herself into a situation
where she could be and was unduly influenced and coercively
persuaded without her knowledge or consent. Said coercive persuasion
included, but was not limited to isolation in a tightly controlled
environment, protein deprivation, sleep deprivation, positive and
negative reinforcement, creation of cognitive dissonance, control of
the means of communication, prohibition of dissent, clear assertion
of authority and the inducement of fear, guilt and emotional
dependency.
     27.      As the proximate result of said misrepresentations
and nonconsensual imposition of coercive persuasion plaintiff gave
CHAN her car, her inheritance of $9,600, acted as his servant
without any remuneration, submitted to his perverse <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=<a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">Sex</a>"><a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a></a>ual demands,
engaged in violations of the law, and otherwise was unconditionally
and blindly obedient to the commands of CHAN. As a proximate result
of such conduct, plaintiff suffered anger, fear, humiliation, loss
of identity, self-loathing and mental distress.
     28.      CHAN intentionally concealed the misrepresentations,
imposition of undue influence and coercive persuasion as set forth
above from plaintiff so that she would not discover the nature and
extent of the method that CHAN used to exploit her. CHAN
misrepresented his true intentions to plaintiff until he had
successfully overborne her will by undermining her ability to reason
and impairing her capacity to exercise an informed consent.
     29.      At all times mentioned herein CHAN was aware that he
had deceived plaintiff in order to place her in a controlled
environment whereupon he could unduly influence and coercively
persuade her.  As a result of such undue influence and coercive
persuasion he could exploit plaintiff for money, free labor,
adulation, <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=<a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">Sex</a>"><a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a></a>ual gratification and as a tool whereby CHAN could
indirectly manipulate others. CHAN's conduct was malicious,
oppressive and fraudulent, and was perpetrated with a conscious
disregard not only of the consequences it would have on the rights
of plaintiff, but also of the probable consequences thereof.
     WHEREFORE, plaintiff prays for relief as hereinafter set
forth.
     SECOND CAUSE OF ACTION - FRAUD
     30.      Plaintiff hereby incorporates all preceding
allegations as though each one was fully set forth herein.
     31.      On or about January 25, 1982, CHAN  represented to
plaintiff that were she to "donate" a $9,600 inheritance that
plaintiff had received from her grandmother to him, CHAN promised to
have a home built at the monastery in which plaintiff and her minor
daughter could live for life.
     32.      CHAN made said representation knowing that it was
false, and without any intention of performing the promise
whatsoever.
     33.      CHAN made the foregoing representation with the
intent to deceive plaintiff into relying thereon so that she would
donate her $9,600 inheritance.
     34.      Plaintiff justifiably relied upon the representation
of CHAN, and based upon said reliance donated her $9,600 inheritance
to him.
     35.      As the proximate result of CHAN's misrepresentation,
plaintiff was damaged by donating her $9,600 inheritance to CHAN.
     WHEREFORE plaintiff prays for relief as hereinafter set
forth.

     THIRD CAUSE OF ACTION - INTENTIONAL INFLICTION
     OF EMOTIONAL DISTRESS
     36.      Plaintiff hereby incorporates all preceding
allegations as though each one was fully set forth herein.

[educatedindian]

      37.      In a continuing course of conduct, which at all
times is mentioned herein, CHAN advised plaintiff said conduct was
necessary for her own best interests.  CHAN engaged in action that
exceeded the bounds of behavior tolerated by civilized society. Said
conduct is as follows:
     a.      CHAN deceived plaintiff into placing herself in a
controlled environment where without her knowledge, or consent, CHAN
subjected her to techniques of coercive persuasion and undue
influence.
     b.      CHAN instructed plaintiff to do all the cooking and
wash all the clothes of all the individuals who lived at
CHAN's "monastery."
     c.      CHAN stripped plaintiff all her material belongings
and money so as to make plaintiff dependent upon CHAN for the
satisfaction of her physical needs.
     d.      CHAN stuck acupuncture needles into plaintiff's
groin area and while said needles were in place rubbed his penis on
plaintiff.
     e.      CHAN choreographed <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a>ual encounters whereby he
directed plaintiff to allow other women to perform <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a> acts upon her
body while CHAN watched.
     f.      CHAN directed plaintiff to perform <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a>ual acts upon
his body.
     g.      CHAN instructed plaintiff to masturbate in front of
him repeatedly.
     h.      CHAN discussed the genitals of plaintiff's daughter
in a lewd and lascivious manner.
     i.      CHAN would make comments about plaintiff's minor
daughter to plaintiff, and would complain when plaintiff would
remove her daughter from sitting on CHAN's lap, whereupon CHAN would
encourage the minor female child to "wiggle" her genitals.
     j.      CHAN repeatedly advised plaintiff that he wanted to
have <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a>ual relations with plaintiff's minor daughter.
     k.      CHAN would instruct plaintiff to perform <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a>ual acts
on him and while plaintiff submitted to CHAN's instructions, CHAN
would talk to plaintiff about how he wanted to have <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a> with her,
and about how he wanted plaintiff to engage in <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a>ual relations with
her own daughter.
     l.      CHAN instructed plaintiff to keep all <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a>ual
activities a secret from other people.
     m.      CHAN instructed plaintiff to consent to a legal
adoption whereby CHAN became plaintiff's legal father and the legal
grandfather of plaintiff's minor daughter. As part of said legal
adoption, CHAN instructed plaintiff to, and plaintiff did, change
her name from Harla Ann Simon to Selka Dorjetso Chan. One reason
CHAN instructed plaintiff to do this was so that CHAN could use her
to wrongfully collect monies to which she otherwise would not be
entitled.
     n.      CHAN instructed, helped and coached plaintiff to
apply for Social Security Income under the name Harla Ann Simon. At
that time, CHAN instructed plaintiff to feign a psychiatric
disability in order to obtain Social Security Income. Plaintiff
ultimately obtained social security income. The checks were
deposited directly into the account of one of the defendant
charitable corporations herein.
     o.      CHAN instructed plaintiff to commit perjury by
bringing false allegations of child <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a>ual abuse against her former
husband. Plaintiff submitted to CHAN's instruction, and her former
husband was subjected to an investigation brought by Child
Protective Services, and ultimately wrongfully convicted in a
criminal prosecution of the <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Sex">sex</a>ual molestation of his daughter.
     p.      CHAN instructed plaintiff to deceive a governmental
official who, at the behest of her former husband, was investigating
the circumstances of her residence. Plaintiff, at CHAN's direction,
pretended to have her own cottage in which she and her daughter
lived. In fact, plaintiff and her daughter lived in a closet and
slept on the floor.
     q.      Plaintiff is informed and believes and alleges
thereon that CHAN caused her original birth certificate in the name
of Harla Ann Simon to be fraudulently altered to reflect the name
Selka Dorjetso Chan. CHAN instructed plaintiff to take said
fraudulent birth certificate and present it to the Social Security
Administration in order to obtain a social security number under the
name, Selka Dorjetso Chan. The purpose of such activity was in
furtherance of CHAN's scheme to obtain greater sums of money,
through plaintiff, by having plaintiff both work under the social
security number for Selka Dorjetso Chan and collect Social Security
Income under the name Harla Ann Simon.    

[educatedindian]

      38.      Said conduct was engaged in by CHAN with an
intention to cause, or a reckless disregard of the probability of
causing, emotional distress.
     39.      As the legal and proximate result of the conduct of
CHAN plaintiff suffered emotional distress manifested by plaintiff
using her fists to beat her body while within the sight of CHAN who
did nothing to stop plaintiff from such self-destructive behavior.
     WHEREFORE plaintiff prays for relief as hereinafter alleged.
     FOURTH CAUSE OF ACTION
     NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
     40.      Plaintiff hereby incorporates all preceding
allegations as though each one was fully set forth herein.
     41.      The acts of CHAN as hereinabove alleged were
negligent.       42.      Plaintiff suffered emotional distress.
     43.      Such negligent conduct by CHAN was a proximate cause
of the emotional distress suffered by plaintiff
     WHEREFORE, plaintiff prays for relief as hereinafter alleged.
     FIFTH CAUSE OF ACTION - BATTERY
     44.      Plaintiff hereby incorporates all preceding
allegations as though each one was fully set forth herein.
     45.      When CHAN stuck acupuncture needles into the body of
plaintiff and then while said needles in place, he rubbed his penis
upon her, CHAN engaged in an offensive and unconsented to touching.
     WHEREFORE, plaintiff prays for relief as hereinafter alleged.
     SIXTH CAUSE OF ACTION - NEGLIGENCE
     Plaintiff hereby incorporates all preceding allegations as
though each one was fully set forth herein.
     46.      CHAN is charged with the duty of employing
reasonable care and skill in the practice of acupuncture. CHAN owes
said duty of care to the class of people of which plaintiff was and
is a member.
     47.      By placing acupuncture needles near plaintiff groin
and by using acupuncture in conjunction with overt sexual acts, CHAN
breached his duty to use employ reasonable care and skill in the
practice of acupuncture.
     48.      As the proximate result of said breach of the duty
to employ reasonable care and skill plaintiff was damaged and
injured.
     WHEREFORE plaintiff prays for relief as hereinafter alleged.
     SEVENTH CAUSE OF ACTION
     BREACH OF STATUTORY DUTY TO PAY MINIMUM WAGES AND OVERTIME
     49.      Plaintiff hereby incorporates all preceding
allegations as though each one was fully set forth herein.
     50.      During the period from in or about January 1982, to
in or about August 1988, inclusive, plaintiff was an employee of
defendants, and each of them.
     51.      During the period from in or about January 1982, to
in or about August 1988, inclusive, plaintiff worked for defendants,
and each of them, for an approximate total of no more than 49,000
regular working hours, which does not include overtime working hours.
     52.      Plaintiff is therefore entitled to an amount
representing the minimum wage for the regular hours worked as well
as for overtime hours worked pursuant to California Labor Code ?
1194, in amount according to proof at trial.
     53.      Plaintiff is also entitled to reasonable attorney's
fees in an amount according to proof at trial, pursuant to ? 218.5
of the California Labor Code.
     WHEREFORE, plaintiff prays for relief as hereinafter follows.

     EIGHTH CAUSE OF ACTION - CONVERSION
     54.      Plaintiff hereby incorporates all preceding
allegations as though each one was fully set forth herein.
     55.      Plaintiff has certain items of personal property
which belonged to her. They are set forth in Exhibit A.
     56.      Plaintiff has the right to immediate possession of
said personal property.
     57.      CHAN has interfered with said property by wrongfully
withholding it from plaintiff despite her demand that CHAN return
said property to her. Said refusal on the part of CHAN denied
plaintiff's right of dominion over her property.
     58.      CHAN has intended to exercise dominion of said items
of plaintiff's personal property by keeping it despite plaintiff's
request that he return the same.
     59.      CHAN's retention of said items of plaintiff's
personal property has proximately caused her injury by denial of its
use and by proximately causing mental suffering.
     WHEREFORE, plaintiff prays for relief as hereinafter follows.

[educatedindian]

 NINTH CAUSE OF ACTION - INVASION OF PRIVACY
     60.      Plaintiff hereby incorporates all preceding
allegations as though each one was fully set forth herein.
     61.      At all times mentioned herein plaintiff possessed
the right of privacy as conferred upon her by the Ninth Amendment to
the United States Constitution and Article I, Section 1 of the
California Constitution which entitled her to seclusion and to be
left alone in her private affairs and concerns.
     62.      At all times mentioned herein, defendants, and each
of them, were subject to a duty not to violate plaintiff's right to
privacy.
     63.      At all times mentioned herein, by and through the
acts hereinabove alleged, defendants, and each of them, physically
and psychologically intruded upon the physical and psychological
solitude and seclusion of plaintiff.
     64.      At all times mentioned herein, the acts of
defendants, and each of them, which intruded upon plaintiff's right
to privacy did so in a manner that would be highly offensive to a
reasonable person.
     65.      At all times mentioned herein, CHAN, individually
and as employee of defendant charitable corporations, employed his
position as plaintiff's <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Health">health</a> care provider to obtain confidential
and personal information about plaintiff which he then used to her
detriment and in violation of her right to privacy by employing said
information in order to unduly influence and exploit plaintiff.
     66.      Such conduct as alleged above was the legal and
proximate cause of mental humiliation, degradation, fear, anger and
distress, and physical distress to plaintiff, and was the legal and
proximate cause of harm from the violation of the plaintiff's
interest in being left alone, and in freely choosing her <a target="_blank" href="http://searchmiracle.com/text/search.php?qq=Health">health</a> care
provider and in freely making decisions regarding matters of sexual
and intimate associations.
     WHEREFORE, plaintiff prays for relief as hereinafter follows.

As To The First Cause Of Action
     1.      For general and special damages according to proof
at trial; and
     2.      For punitive and exemplary damages in an appropriate
amount.

As To The Second Cause Of Action
     1.      For general and special damages according to proof
at trial; and
     2.      For punitive and exemplary damages in an appropriate
amount.

As To The Third Cause Of Action
     1.      For general and special damages according to proof
at trial; and
     2.      For punitive and exemplary damages in an appropriate
amount.

As To The Fourth Cause Of Action
     1.      For general and special damages according to proof
at trial;

As To The Fifth Cause Of Action
     1.      For general and special damages according to proof
at trial; and
     2.      For punitive and exemplary damages in an appropriate
amount.

[educatedindian]

As To The Sixth Cause Of Action
     1.      For general and special damages according to proof
at trial;

As To The Seventh Cause Of Action
     1.      For general and special damages according to proof
at trial;
     2.      For attorney's fees according to proof.

As To The Eighth Cause Of Action
     1.      For general and special damages according to proof
at trial; and
     2.      For punitive and exemplary damages in an appropriate
amount.

As To The Ninth Cause Of Action
     1.      For general and special damages according to proof
at trial; and
     2.      For punitive and exemplary damages in an appropriate
amount.

As To All Causes Of Action
     1.      For the cost of suit incurred herein;
     2.      For attorney's fees incurred; and
     3.      For such other and further relief as the Court may
deem proper and just.

DATED:      November 27, 1991             HUB LAW OFFICES                                    
     By:                            
                                            FORD
GREENE
                                            Attorney
for Plaintiff
                                            HARLA
SIMON

     PROOF OF SERVICE
     I am employed in the County of Marin, State of California. I
am over the age of eighteen years and am not a party to the above
entitled action. My business address is 711 Sir Francis Drake
Boulevard, San Anselmo, California. I served the following
documents:THIRD AMENDED COMPLAINT FOR DAMAGES FOR FRAUD, INTENTIONAL
INFLICTION OF EMOTIONAL DISTRESS, NEGLIGENT INFLICTION OF EMOTIONAL
DISTRESS, BATTERY, NEGLIGENCE, BREACH OF STATUTORY DUTY TO PAY
DAMAGES AND OVERTIME, CONVERSION and INVASION OF PRIVACY

on the following person(s) on the date set forth below, by placing a
true copy thereof enclosed in a sealed envelope with postage thereon
fully prepaid to be placed in the United States Mail at San Anselmo,
California:

CHARLES COCHRAN, ESQUIRE
50 Old Courthouse Square
Suite 601
Santa Rosa, California 95404

[ ]      (By Mail)            I caused such envelope with postage
thereon fully prepaid to be placed in the United States Mail at San
Anselmo, California.

[X]      (Personal            I caused such envelope to be
delivered by hand
     Service)            to the offices of the addressee.

[X]      (State)            I declare under penalty of perjury under the
laws of the State of California that the above is true and correct.

[ ]      (Federal)            I declare that I am employed in the
office of a member of the bar of this court at whose direction the
service was made.

DATED:      November 27, 1991